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Caffeine AI Privacy Notice

Last Updated: July 20, 2026

Introduction

This Privacy Notice (“Notice”) describes how Caffeine Labs AG, a corporation established under Swiss laws, including its subsidiaries and affiliates (collectively, ”Caffeine Labs”, "we," "our," or "us"), processes personal data about you when you visit https://caffeine.ai/ (the “Website”). Please read this Notice carefully to understand our practices regarding your personal data (sometimes referred to in various privacy laws as “personal information”).

Caffeine Labs is the controller of your personal data. The contact details of our EU Representative can be found below under the “Contact Us” section below.

This Notice does not apply to any other data processing, including, without limitation, personal data we collect via other websites that do not link to this Notice.

Source of Personal Data We Process

Personal Data You Provide. We may process personal data you directly provide us when you visit the Website, subscribe to updates, request more information on the Website (such as your name and email address), or when you message us via Caffeine.ai.

Data We Process Automatically. We may automatically process certain data, including some that can be considered personal data, when you use our Website, such as your internet protocol (IP) address, mobile device identifier, browser type, browser user-agent, operating system, internet service provider, pages you visit before and after using the Website, time and date of your visit, information about the links you click and pages you view within the Website, and other standard server log information. We may collect such information via the use of cookies, pixel tags, local shared objects, and similar technologies to automatically collect this information. More information on our use of cookies can be found in our sections on Cookies below.

Communications. If you communicate with us (such as contacting customer support), or engage in our surveys or feedback requests, we collect the contents of such communications. We also collect details of communications that we send you (such as through emails), and information about your interaction with these communications. When you use the Caffeine AI tool, we may use anonymized or aggregated information you submit through the prompt to train the Caffeine AI tool to continue to improve its performance, but will not use personally identifiable information about you to train the tool.

We do not share your personal data collected via the Website with third parties, except with those third party services, explained further below, which help us conduct our business or, in the case of third-party advertising or analytical cookies and pixels, with your consent.

Purpose of Processing

We process your personal data to provide, maintain, improve, and promote the Website, and to communicate with you. In particular:

  • To research, analyze and improve the Website’s performance
  • To create a user account
  • To identify and track visitors to our Website
  • To send you marketing and information updates about Caffeine.AI at your request
  • For safety, security, and fraud prevention of the Website
  • To investigate, prevent, and detect prohibited or illegal activities and other security or technical issues
  • To investigate, troubleshoot and respond to all customer support queries you send to us, which may include reviewing session details you had during your use of the Caffeine AI tool
  • To comply with and to satisfy applicable law, regulation, legal process, or governmental request
  • To fulfil our Terms of Use and comply with our legal obligations
  • As necessary for our (or others’) legitimate interests, including our interests in providing a safe, efficient and personalised service to our users or the public, unless such processing outweighs any risks to your interests or fundamental rights or freedoms that require protection of your personal data

Legal Basis for Processing

We process your personal data in accordance with applicable data protection laws, including the UK and EU General Data Protection Regulation, if:

  • You have given your consent,
  • It is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract,
  • It is necessary for compliance with legal obligations to which we are subject or
  • It is necessary for the purposes of our legitimate interest or those of third parties in particular our legitimate interest to pursue the purposes described in this Notice

Data Sharing and Recipients

We limit the disclosure of your personal data to others. However, we share personal data with people and businesses that help operate the Website and carry out our business (referred to as our third-party processors or service providers), and when we are legally permitted or required to do so. We also share personal data when an individual requests we share it.

Authorized third parties. We may share your personal data with Third-Party Services who support the Website, such as customer service and support services (e.g., call centre, help desk or customer relationship management providers), finance and accounting services (e.g., accountants, banks, credit check agencies, insurers, payment processors or tax advisors), IT and telecommunications services (e.g., cloud service providers, data hosting centres, software providers, IT maintenance and support providers, electronic communication services providers, or network operators), recruiting management, marketing and sales services (e.g., marketing and advertising, social media platforms or other media companies).

Professional advisors. We may disclose your personal data to lawyers, accountants, insurers, information security and forensics experts.

Competent law enforcement, government regulators and courts. We may disclose your personal data to respond to legal process, law enforcement requests, subpoenas, court orders, legal claims or government inquiries, to detect fraud, and to protect and defend the rights, interests, safety, and security of the Website, our affiliates, owner, users, or the public.

Potential or actual acquirers or investors and their professional advisors. We may share your personal data in connection with a substantial corporate transaction, such as the sale of a Website, a merger, consolidation, sale of certain assets, or in the unlikely event of bankruptcy.

With your consent. We may share data for any other purposes disclosed to you at the time we collect the data and pursuant to your consent.

Cookies and Social Media

You may be able to access Third-Party Services, such as social media or messaging services, through the Website or even while logged into those accounts, to share any information about your experience on the Website with others, but you must note that these services and how they function in relation to our Website may not be fully within our control. These Third-Party Services may be able to collect information about you, including your activity on the Website, and they may notify your connections on the Third-Party Services about your use of the Website, in accordance with their own privacy policies. We encourage you to visit their websites and review their privacy and use policies, and adjust your privacy settings on their websites accordingly.

A cookie is a piece of information that is placed automatically on your computer’s hard drive when you access certain websites. The cookie uniquely identifies your browser to the server. Cookies allow us to store information on the server (for example language preferences, technical information, click or path information, etc.), to help make the web experience better for you, to conduct website analysis and website performance review, and to serve you with relevant advertisements.

We use strictly necessary cookies to operate the Website (such as keeping you signed in), and, with your consent where required, analytics and advertising cookies (including Google and Datadog services) to understand how the Website is used and to measure our advertising. You can accept or reject non-essential cookies via the cookie banner, and change your choice at any time via the “Cookie Settings” link in the Website footer.

Most web browsers are set up to accept cookies, although you can set your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of the Website may not work properly if you refuse cookies.

Do Not Track

We partner with third parties to display advertising on our websites or to manage our advertising on other websites. Our third-party partners use cookies, web beacons, LSOs, tags, scripts, and similar technologies to gather information about you over time and across different websites or applications to help predict your preferences and show you ads on sites across the Internet. You can manage your cookie preferences directly with us at any time via the “Cookie Settings” link in the Website footer, or by contacting us.

Third Country Transfers

If you are located in the EU/EEA/UK and we transfer your personal data to recipients in countries outside of your home jurisdiction (“Third Countries”), we apply the following safeguards to ensure the protection of your personal data is not undermined:

For more details about our Third Country transfers or copies of these safeguards please reach out to us via any of the methods in the below “Contact Us” section.

Data Retention

We store your personal data for no longer than is necessary for the purposes described in this Notice. To determine our storage periods, we particularly use the following criteria:

  • If you withdraw your consent or object to the processing of your personal data and we cannot rely on another legal basis, we will usually not store your personal data for any longer;
  • If we are legally obliged to retain your personal data, we will usually store your personal data for the prescribed retention period;
  • If we are legally obliged to delete your personal data, we will usually not store your personal data for any longer;
  • If we need your personal data to establish, exercise, or defend legal claims, we will usually store your personal data for the statutory limitation period or until legal proceedings are concluded;
  • If we have an existing relationship with you, we will usually store your personal data for the period of our relationship;
  • If we likely need to use your personal data in the future, we will usually store your personal data for this anticipated period in the future.

Your Rights

Under applicable data protection and privacy laws, you may have the following rights

  • Right to withdraw consent: you can withdraw your consent at any time;
  • Right of access/know to personal data: you can ask us to provide access to your personal data;
  • Right to rectification/correction: you can ask us to rectify inaccurate personal data or complete incomplete personal data;
  • Right to erasure/delete: you can ask us to delete your personal data;
  • Right to restriction of processing: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to transfer your personal data to you or to another recipient at your choice;
  • Right to appeal: you may have the right to appeal our decision regarding a request using the contact information below. Please use the same email address that you used to submit the initial privacy rights request when you submit your Request to Appeal and please add “Request to Appeal” in the subject line of the email. If you do not use the same email address, we cannot link your request to appeal to your initial privacy rights request.
  • Right to object: you can object to the processing of your personal data.

To exercise these rights, please contact us using the information below.

We do not discriminate or retaliate against you if you choose to exercise these rights.

You also may designate an authorized agent to make a request on your behalf. If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. Alternatively, your authorized agent may provide evidence of having power of attorney or acting as a conservator for you. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.

Please note that your rights can be restricted in certain situations. In such case, we will inform you of the restriction’s reason. If you have any concerns about how we process your personal data, we encourage you to let us know so we can try to resolve your concerns.

The enforcement of your rights is governed by applicable data protection laws. In Switzerland, you can take civil action for a breach of your personal rights, file a criminal complaint for a breach of the Data Protection Act, or inform the Federal Data Protection and Information Commissioner. You may have this right if the data protection laws of a country other than Switzerland apply to you and if you think we have not complied with data protection laws, having the right to lodge a complaint with the competent supervisory authority. Under certain U.S. state privacy laws, to the extent applicable, you may also have the right to appeal this decision or to contact that State’s Attorney General if you have concerns about the results of the appeal.

Data solely retained for data backup purposes is principally excluded from these rights until it is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.

For requests under certain applicable US privacy laws, these rights may not apply to pseudonymous data if the information necessary to identify the individual is kept separately and is subject to controls that prevent access to the information. Pseudonymous data, for these purposes, is personal data that can no longer be attributed to a specific individual without the use of additional information, if the additional information is kept separately and is subject measures to ensure that personal data is not attributed to the specific individual.

Responding to Your Rights Request

When you exercise these rights and submit a request to us, we may verify your identity by asking you for the following pieces of information: your relationship with us, first and last name, email address, and place of residency.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will use the personal data you provide to us when submitting a consumer request only to verify the requestor’s identity or authority to make the request.

Depending on your jurisdiction, we have between 30 and 90 days to respond to your request. If we require more time, we will inform you of the reason and extension period in writing.

Please note that depending on your jurisdiction (not applicable for EU/UK), we are only obligated to respond, free of cost, to requests from the same consumer up to two times in a 12-month period. Depending on your jurisdiction, after you have exceeded the applicable number of requests, we have the right to charge a reasonable fee for fulfilling the request. In addition, under the applicable state privacy law, and for the protection of your personal data, we may be limited in what personal data we can disclose.

Depending on your jurisdiction, we may maintain your rights requests for at least 2 years. This information will not be used for any other purpose except to review compliance processes; it will not be shared except as necessary to comply with a legal obligation.

Security

We implement reasonable and appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

Unfortunately, the transmission of information is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures.

Miscellaneous

Provision of your personal data may be necessary for us to fulfil our contractual obligations or to comply with statutory requirements. In some instances, providing personal data is required to enter into or perform our contract; if you choose not to provide such information, we may be unable to provide you with certain services or fulfil our obligations under the contract.

We do not engage in automated decision-making, including profiling, that produces legal effects or similarly significant consequences for you. Should this practice change, we will update this Notice to provide clear information about the logic involved, as well as the significance and envisaged consequences for you.

Shine the Light Law

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to[email protected].

Changes to This Notice

We may update this Notice from time to time. We will notify you of any changes by contacting you at your contact details provided to us and/or posting the new Notice on this page and updating the "Last Updated" date.

Children's Privacy

The Website is not directed to children under 18. We do not knowingly collect personal data from children under 18 without parental consent.

Third-Party Links

The Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements. If you submit personal data to any third-party websites or service providers, your information is governed by their privacy policies. When you leave our websites, we encourage you to read the privacy policies on every website you visit.

Social Media

We may also include applications or widgets from social media providers that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, may be visible to you on our Website. Integration between our Website and social media networks such as Facebook, X and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal data transmitted to that network.

Contact Us

If you have any questions about this Notice or our practices, please contact us at:

Caffeine Labs AG
Genferstrasse 11
8002 Zurich
Switzerland
Email: [email protected]

Caffeine’s EU representative for data protection matters is an external contact at Eversheds Sutherland Netherlands B.V., as appointed to handle GDPR compliance. You can contact this EU representative via email at [email protected] or by post, ensuring "EU Representative" is included in the subject line.

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