Privacy Policy

Controller: Valinorsk LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, United States. Email: hello@xpanion.com. Phone: +1 307 218 8332.

Representative

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

• European Union (EU)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/12875832842

powered by Prighter

Xpanion processes your meetings on your own machine. Your audio, transcripts, minutes, projects, notes and time records stay on your computer. They are not sent to us, we cannot read them, and we cannot recover them for you.

What we do receive is limited to what is needed to sell you a license, keep that license valid, deliver the software, and answer you when you write to us or leave us a voicemail.

We do not use your meeting content to train any model. We could not: it never reaches us.

• Audio is held in memory while a meeting is recorded, is never written to disk, and is not transmitted.
• Transcripts, summaries, minutes, action items, boards, timelines and time records are stored locally and are not transmitted, apart from what a Corporate seat shares with its organization's own hub (below).
• File names, project names, participant names and speaker labels are not transmitted, apart from what a Corporate seat shares with its organization's own hub (below).
• We operate no analytics, telemetry, crash reporting or session recording inside the application.

INV-1Audio is never written to disk

Capture lives in memory and is discarded the instant it's processed. There is no recording file to leak, subpoena, or lose.

INV-2Meeting data never leaves your Mac

Transcripts, minutes, and plans stay on your machine. Nothing from your meetings ever leaves your Mac — Xpanion only checks your license, downloads its models once, and looks for updates.

INV-3Nothing is trained on your data

The model runs locally on Apple silicon. Your conversations are never used to improve anyone's model — ours or otherwise.

INV-4Voiceprints vanish

Speaker separation happens in memory and is never stored or linked across meetings. The voiceprint exists for the length of the meeting, then it's gone.

Xpanion connects to the internet for the license check (section 4.1), the model download (section 4.4), and the update check and the update download (section 4.5).

On a Corporate seat connected to your organization's own hub, Xpanion signs in to that hub with the enrollment token your organization gave you and exchanges with it the projects and cards you share with your team — with their comments and activity — your team's member list, and the output-folder settings of your team and your organization; private cards are never sent, and the hub is run by your organization, not by us. Whether that connection is encrypted depends on the hub address your organization sets: an https address is, an http address is not.

4.1 License activation and validation

Xpanion checks your license over the internet when you activate it, re-check it or change your plan, when you return to Xpanion shortly after opening the payment page, and periodically after that.

Data: The license check sends your license key, an identifier derived from your machine, and the version of Xpanion you are running; our license service also sees your IP address.

Purpose: binding a license to a machine, enforcing a per-seat subscription, preventing fraud.

Basis: Art. 6(1)(b) GDPR (performance of the contract); Art. 6(1)(f) for fraud prevention.

Retention: 90 days, after which validation records are deleted. Your license and account records are kept for as long as the subscription runs (section 4.2) — this retention concerns the individual validation calls only.

It carries nothing about your meetings, your recordings or your project data.

4.2 Account and subscription

Data: email address, authentication credentials in hashed form, plan, subscription status, license keys issued to you; for Corporate, the seat assignments your administrator makes.

Purpose: providing and administering the subscription.

Basis: Art. 6(1)(b).

Retention: for the life of the subscription and afterwards for as long as needed to handle renewals, disputes and refunds; then deleted.

4.3 Payment

We do not receive or store your card details. Payments are processed by Stripe as merchant of record. We receive confirmation of payment, the plan purchased, and the billing country — the last because tax treatment depends on it.

Basis: Art. 6(1)(b); Art. 6(1)(c) for the tax records.

Retention: for the period required by applicable tax law.

4.4 Model downloads

After you activate a license, Xpanion downloads the speech and language models it runs from Hugging Face, with our own mirror as a fallback, and keeps them on your Mac. If a model is missing later, Xpanion downloads it again the same way.

The model download carries no license key, no machine identifier and no account data; Hugging Face, or our mirror when it is used, sees your IP address.

On macOS 26 or later, the same step asks macOS to download Apple's speech-recognition assets for English and German, which macOS fetches from Apple.

Basis: Art. 6(1)(b).

4.5 Updates

Xpanion checks for a newer version shortly after it starts and every six hours while it runs, with or without an active license. The update check and the update download go to our update storage at Vercel and carry no license key, no machine identifier and no account data; Vercel sees your IP address.

A newer version is downloaded from the same storage, and its signature is verified before it is installed.

Basis: Art. 6(1)(b) while you have a subscription, and Art. 6(1)(f) — our legitimate interest in shipping security fixes — in every case, including without an active license.

4.6 Email we send you

Transactional email — license key, receipts, renewal and expiry notices, cancellation confirmations, replies to your messages.

Basis: Art. 6(1)(b).

Product announcements — occasional news about our own products and additions to Xpanion. We send these only to people who have bought from us and only about our own similar products.

Basis: Art. 6(1)(f), together with the existing-customer exception in Art. 13(2) of the ePrivacy Directive as implemented in your country.

You can opt out at any time, in every such message and by writing to hello@xpanion.com. Opting out does not stop transactional email: you will still get your license key and your receipts.

4.7 When you contact us

If you write to hello@xpanion.com, we receive your message, your address and whatever you choose to tell us.

Our phone number goes to voicemail: calls are not answered in person, and the voicemail service records your message and transcribes it automatically. If you call, we receive your number and, if you leave a message, its recording and transcript. The voicemail service is provided by OpenPhone Technologies, Inc. ("Quo").

Please do not send us meeting recordings, transcripts or minutes.

Basis: Art. 6(1)(b), or Art. 6(1)(f) where you are not a customer.

Retention: as long as needed to resolve the matter and handle any follow-up, for voicemail recordings and their transcripts as well.

4.8 Downloading the app

The download button on xpanion.com/download leads to our portal at portal.xpanion.com, which forwards your browser to the installer file in our storage at Vercel (Vercel Blob). Vercel delivers the file as our processor and sees your IP address.

The portal uses your IP address to count downloads per address within a one-hour window, so that the file cannot be pulled over and over, and for nothing else. The count is held in the working memory of the server instance that answers; it is never written to a database or a log, and it is not linked to an account, an order or a license. After the hour, the entry is dropped at the latest when that server instance next handles a request at the download address (portal.xpanion.com/download/current), or when it shuts down.

Data: IP address.

Purpose: delivering the installer and limiting misuse of the download.

Basis: Art. 6(1)(f) — our legitimate interest in delivering the software and keeping its distribution from being misused.

xpanion.com is a static marketing site.

It sets no cookies, uses no local storage, and loads nothing from a third-party domain. Typefaces are served from our own origin. This is verified against the build rather than by eye: a browser-level census of every request each route makes is recorded in the build output and reports no request leaving our origin.

Server logs. Our hosting provider automatically records standard technical request data — IP address, page requested, date and time, browser and operating system — to deliver the page and keep the service secure. These logs are not combined with other data and are not used to identify you.

The download button leads to our portal at portal.xpanion.com; section 4.8 describes what happens there.

Basis: Art. 6(1)(f).

This is the part that matters most, and the responsibility is yours, not ours.

When you record a meeting, you process the personal data of everyone in it — their voice, what they said, and often their name. Under the GDPR you are the controller of that data.

We are neither controller nor processor of it, because it never reaches us. There is no data-processing agreement to sign with us for meeting content, and we could not offer one meaningfully: we hold nothing to process.

The obligations that come with recording are therefore yours: informing participants, obtaining consent where required, honoring their requests, and keeping the recordings secure on your machine. Xpanion's consent features are record-keeping aids. They do not discharge those obligations and they do not establish that consent was validly given.

For a Corporate seat connected to your organization's own hub (section 3), the same holds for what it shares there: that data stays with your organization, and your organization is the controller.

The current list, with roles, is at /subprocessors/.

None of them receives meeting content, because we do not have it to pass on. We do not sell personal data and we do not share it for advertising. We may disclose data where we are legally required to — and we can only produce what we hold, which does not include anything about your meetings.

Valinorsk LLC is established in the United States, and our providers process data in the United States and, in some cases, elsewhere. If you are in the EEA, the United Kingdom or Switzerland, your account, subscription and support data, what the license check, the update check, the update download and the model download send, the IP address the app download is delivered to, and any voicemail you leave are transferred outside your country.

Each of these providers is engaged under its own terms; if you would like the current detail for a specific provider, write to us or to our representative in section 1.

Retention is stated with each purpose in section 4. Your meeting data has no retention period here, because we never hold it. It lives on your machine and is deleted when you delete it.

If the GDPR or a comparable law applies to you, you have the right to access your data, to rectification, to erasure, to restriction of processing, to object to processing based on our legitimate interests (Art. 21), and to data portability. Where processing rests on consent, you may withdraw it at any time with effect for the future.

Write to hello@xpanion.com, or to our EU representative in section 1. We will answer within one month.

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement.

Two things we cannot do:

• We cannot give you a copy of your meeting data, or delete it for you. We do not have it. The application's own export and delete functions are the way to reach it.
• We cannot act on a request from someone you recorded. If a meeting participant asks us for their data, we have none, and we will tell them to contact you.

If you are a California resident, you have comparable rights under the CCPA, including the right not to be discriminated against for exercising them. We do not sell or share personal information as those terms are defined there.

Account credentials are stored hashed. Traffic between the application and our services is encrypted in transit. Access to the systems that hold account data is limited to those who need it.

The strongest security property of Xpanion is structural rather than procedural: the sensitive material never leaves your machine, so it cannot be taken from us. The corollary is that securing your own machine — disk encryption, screen lock, backups — is the part that protects your meetings, and that part is yours.

Xpanion is not directed at children and is not intended for use by anyone under 16. We do not knowingly collect data from children.

We may update this notice. The current version is always available at https://xpanion.com/privacy/ and inside the application. Where a change materially affects how we handle your data, we will tell you before it takes effect.

Version history:

• 1.2: the app download through our portal added to the privacy policy (section 4.8)
• 1.1: network disclosures aligned with app 1.0.5