Privacy Policy
Effective date: 7 April 2026 · LevelUp Business Management Pty Ltd (ABN 30 628 424 215)
Short version: Frank stores your notes, documents, and reminders to help you remember things. Your data is yours — you can export or delete it anytime. Photos you send are processed for text extraction but never stored as images.
🇦🇺 Australian Privacy Act 1988
🇪🇺 GDPR Compliant
🇬🇧 UK GDPR
No ads, ever
1. What we store
- Account info: your name, email address, and encrypted password
- Notes (snippets): text you type or dictate to Frank
- Documents: files you upload (PDF, DOCX, TXT) — stored in your encrypted vault
- Reminders: scheduled reminders you create, including date and recurrence settings
- Conversation summaries: Frank maintains a running summary of important things you've shared to personalise future responses
- Calendar data: if you connect Google Calendar or Outlook, we store event titles, dates, and times to give Frank context. You can disconnect at any time.
- Family connections: names and relationship details you add so Frank understands your household
- Push notification tokens: device tokens for iOS and Android to deliver reminders
- Telegram/WhatsApp chat ID: if you connect a messaging account, we store only the numeric chat ID to send you reminders
- Subscription data: billing info is handled by Stripe — we never store card numbers
2. Photos and document scans
When you send a photo or scan to Frank:
- The image is sent to a vision service for text extraction
- We use a strict, hardcoded prompt — your photo is never paired with user-supplied instructions
- The raw image is deleted immediately after text extraction — it is never written to disk or stored in your vault
- EXIF metadata (GPS, device info) is stripped before processing
- Only the extracted text is saved to your vault — with your confirmation
📸 Your photos are processed ephemerally. We see only what the text says, not the image itself.
3. How we use your data
- To answer your questions using your own vault content
- To send you reminders via push notification, Telegram, or WhatsApp
- To personalise Frank's responses using your conversation history and calendar context
- To maintain your account and subscription
- To improve service reliability and fix bugs
We do not use your data to train AI models. We do not sell your data. We do not use your data for advertising.
3a. Legal basis for processing (GDPR)
If you are in the EEA or UK, our legal basis for processing your data is:
- Contract performance — providing the FrankLife service, sending reminders, managing your subscription
- Legitimate interests — service reliability, security monitoring, improving Frank's responses using your history
- Legal obligation — retaining payment records as required by law
4. Security
- Passwords are hashed with bcrypt — we cannot recover your password
- All data is encrypted at rest on our servers
- Sessions use secure, HTTP-only, same-site cookies
- Rate limiting and login lockout protect against brute-force attacks
- File uploads are validated by MIME type — not just extension
5. Your rights
Under the Australian Privacy Act 1988 and GDPR, you have the right to:
- Access your data:
GET /api/account/export — download everything as JSON
- Delete your data:
POST /api/account/delete in the app, or email support.franklife@lvlup.org with subject "Data Deletion Request". We will delete your data within 30 days.
- Correct your data: update it in Settings, or contact support.franklife@lvlup.org
- Portability: your exported JSON is human-readable and machine-parseable
- Restrict processing: contact us to limit how we use your data in certain circumstances
- Object to processing: you may object to processing based on legitimate interests
- Withdraw consent: where processing is based on consent, you may withdraw at any time
EEA and UK users: You have the right to lodge a complaint with your national data protection authority. Find your local authority at edpb.europa.eu. We will respond to all data subject requests within 30 days.
6. Data retention
- Account and profile data: retained until you delete your account
- Conversation summaries and vault: retained until you delete your account or request erasure
- Calendar and contact data: retained until you disconnect the integration or delete your account
- Payment records: 7 years (required by Australian tax law)
- System logs: 90 days
If you delete your account, all personal data is permanently removed within 30 days. Backups containing your data are rotated within 30 days.
7. Third-party services and data processors
- Anthropic PBC (USA): Powers Frank's AI responses. When you chat with Frank, your messages and relevant context (calendar, vault summary, conversation history) are sent to Anthropic's Claude API. Anthropic does not use API data to train their models. Anthropic Privacy Policy
- DigitalOcean LLC: Cloud infrastructure. Your data is stored on servers in Sydney, Australia. DigitalOcean Privacy Policy
- Stripe: Payment processing — we never store card numbers. stripe.com/privacy
- Google: Optional Google Calendar integration and iOS/Android push notifications (FCM). Google Privacy Policy
- Apple: iOS push notifications via APNs. Apple Privacy Policy
- Microsoft: Optional Outlook Calendar integration. Microsoft Privacy Policy
- Telegram/Meta: Optional messaging channels. Governed by their respective privacy policies.
7a. International data transfers
Your data is stored in Australia. When your messages are processed by Anthropic (USA), this is an international transfer. Anthropic operates under standard contractual protections consistent with GDPR requirements.
For EEA/UK users: these transfers are protected by Standard Contractual Clauses (SCCs) or equivalent mechanisms as required under GDPR Chapter V.
7b. Google user data
When you connect Google Calendar or allow push notifications via Firebase Cloud Messaging, FrankLife only accesses the minimum Google user data needed to provide the service:
- Calendar metadata: event titles, start/end times, location, attendees, and reminders — stored encrypted on our DigitalOcean infrastructure in Sydney, Australia.
- Push tokens: device tokens so Google can deliver notifications to you.
We use this Google data solely to show your schedule in FrankLife, create reminders you ask for, and personalise Frank's replies. The data is never sold or used for advertising. Access is limited to the FrankLife application and our support engineers under strict confidentiality.
Sharing/disclosure: Google data is shared only with the processors already listed above — DigitalOcean (hosting/storage) and Anthropic (to generate a reply when you ask Frank a question that references a calendar event). Anthropic receives only the relevant snippet needed to answer your question and contractually may not use it to train their models. We do not share Google user data with any other third party.
You can disconnect Google Calendar anytime from Settings > Integrations, which immediately revokes our access and deletes the cached Google data from our servers.
8. Children's privacy
FrankLife is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, please contact us at support.franklife@lvlup.org and we will delete it promptly.
9. Changes to this policy
If we make material changes to this policy, we will notify you by email or in-app notification at least 14 days before the change takes effect. Continued use of FrankLife after that date constitutes acceptance of the updated policy.
10. Contact
Privacy questions, data subject requests, or complaints:
LevelUp Business Management Pty Ltd (ABN 30 628 424 215)
Email: support.franklife@lvlup.org
Perth, Western Australia, Australia
We respond to privacy enquiries within 5 business days and data subject requests within 30 days.