Back to Xpanion
Legal

Privacy Policy

Xpanion processes your meetings on your own machine, and what reaches us is limited to what it takes to sell you a licence, keep it valid, deliver the software, and answer you when you write. This policy sets out each of those, the legal basis for it, how long we keep it, and the rights you have — including the ones we cannot exercise for you, because we hold nothing to exercise them against.

Last updated 2026-09-07

Version 1.0 · Effective 2026-09-01


1. Who we are, and who represents us in the EU

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

GDPR Certification: Art 27 representation by Prighterpowered by Prighter

Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Vienna, Austria

2. The short version

Xpanion processes your meetings on your own machine. Your audio, transcripts, protocols, 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 licence, keep that licence valid, deliver the software, and answer you when you write to us.

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

3. What Xpanion does not send

  • Audio is held in memory while a meeting is recorded, is never written to disk, and is not transmitted.
  • Transcripts, summaries, protocols, action items, boards, timelines and time records are stored locally and are not transmitted.
  • File names, project names, participant names and speaker labels are not transmitted.
  • 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, protocols and plans stay on your machine. The only thing Xpanion ever sends is a content-free licence check.
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.

The only outbound connections Xpanion makes are those in section 4.

4. What we process, and on what basis

4.1 Licence activation and validation

Data: licence key, an identifier derived from your machine, your IP address as seen by our service.

Purpose: binding a licence 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 licence and account records are kept for as long as the subscription runs (section 4.2) — this retention concerns the individual validation calls only.

The check carries no information about your meetings, your files, or what you do in the application.

4.2 Account and subscription

Data: email address, authentication credentials in hashed form, plan, subscription status, licence 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 download

After activation, Xpanion downloads the speech-recognition model from a distribution endpoint. The download reveals your IP address and nothing that identifies you or your licence beyond that.

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

4.5 Updates

Xpanion checks in the background whether a newer version exists. The check reveals your IP address and the version you are running.

Basis: Art. 6(1)(b), and Art. 6(1)(f) — our legitimate interest in shipping security fixes.

4.6 Email we send you

Transactional email — licence 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 licence key and your receipts.

4.7 When you contact us

If you write to hello@xpanion.com or call our number, we receive your message or your call, your address or number, and whatever you choose to tell us. Please do not send us meeting recordings, transcripts or protocols.

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.

5. The website

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.

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

6. Recordings of other people

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, honouring 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 Corporate deployments processing against an inference endpoint operated by your own organisation, the same holds: the data stays inside your organisation's perimeter, and your organisation is the controller.

7. Who else sees the data we hold

ProviderFunctionWhat it sees
SupabaseDatabase and authentication for the portalAccount and subscription data
VercelHosting for the portal and the marketing siteRequest metadata, IP addresses
StripePayments, merchant of recordPayment data, which we do not receive
ResendSending transactional emailYour email address and the message

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.

8. International transfers

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 is transferred outside your country.

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

9. How long we keep it

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.

10. Your rights

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.

11. Security

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.

12. Children

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

13. Changes

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.


Back to Xpanion