LAYX
Effective Date: 16 October 2026 · Global Edition

Global Privacy Policy

LAYX is engineered from the ground up on a radical privacy-by-design architecture. We do not ask for your legal name, email address, phone number, contacts list, or real-time location. Sensitive gear details are encrypted on your physical device before upload. This policy sets out our global privacy standards and your legal rights worldwide.

1. Who We Are & Data Controller

LAYX is developed and operated by Three Guys s.r.o., a corporation incorporated under the laws of the Slovak Republic, European Union (the “Data Controller” under the EU/UK GDPR and applicable global data protection laws).

2. Architectural Foundations: Zero-Knowledge & Sovereign Identity

Traditional applications collect your personal identity to sell ads, build behavioral dossiers, or monetize social graphs. LAYX fundamentally rejects this paradigm through four mathematical guarantees:

3. Complete Data Inventory & Retention Schedule

We collect and process only the minimal technical and user-provided information strictly necessary to operate the application.

Category & Data Elements Specific Purpose Legal Basis (GDPR / Global) Retention Period
Pseudonymous Callsign & Bio
(e.g. @GRAINLINE, optional short text)
Public identification within the community; displaying your public drops. Contractual necessity (Art. 6(1)(b) GDPR) Retained until you delete your account or change it.
Cryptographic Keys & Technical ID
(Random UUID, hashed token, public E2EE key)
Cryptographic authentication, session management, and routing encrypted pings. Contractual necessity (Art. 6(1)(b) GDPR) Retained until account deletion. Private keys never leave your device.
Public Vault Items
(Make, model, category, specs, photos)
Displaying your gear catalog and allowing item tags in your Daily Drops. Contractual necessity / User consent Retained until item or account deletion.
Sealed Vault Data & Receipt Blobs
(Serial numbers, purchase price, notes, and AES-256-GCM encrypted receipt photos)
Secure private storage for insurance/records. Receipt photos are byte-level encrypted before upload and stored in a private bucket. Ciphertext only. Zero-knowledge to LAYX. Contractual necessity (Art. 6(1)(b) GDPR) Stored as encrypted blobs until item or account deletion. Purged immediately upon account deletion.
Daily Drops
(Sanitized photo, caption, tagged items, timestamp)
Publishing your morning carry to the chronological feed and carry history calendar. Contractual necessity / User consent Retained until you delete the drop or delete your account.
Item Inquiries (Messages)
(End-to-end encrypted message payloads)
Facilitating 1:1 private communication regarding specific gear. Contractual necessity (Art. 6(1)(b) GDPR) Hard deleted automatically after 24 hours.
Community Interactions
(Nods, bookmarks, blocklist, safety reports)
Social appreciation, personal bookmarks, content moderation, and user safety. Contractual necessity / Legitimate interest Retained until account deletion.
Device Tokens & Attestation
(Push token, Apple App Attest / Play Integrity ID)
Delivering morning Drop & Callout alerts; preventing bot abuse and fraudulent registration. Legitimate interest (Art. 6(1)(f) GDPR) / Security Retained until sign-out, device removal, or account deletion.
Database Backups & PITR
(Point-in-time recovery automated snapshots)
Disaster recovery and system resilience. Encrypted at rest using AES-256. Legitimate interest (Art. 6(1)(f) GDPR) / Security Retained for a rolling maximum of 7 days, then automatically purged on backup rotation.
Website Waitlist Email
(Collected exclusively on landing page)
Sending your closed beta (TestFlight / Google Play) invitation link. Consent (Art. 6(1)(a) GDPR) Permanently purged 7 days after your invite is dispatched. Never linked to your in-app account.
Server Access Logs & IP
(Transient network connection logs)
Defending against DDoS attacks, brute force attempts, and server errors. Legitimate interest (Art. 6(1)(f) GDPR) / Security Retained for a rolling maximum of 7 days, then permanently destroyed.

4. What We Never Do (Global Negative Pledge)

5. International Data Transfers & EU Data Residency Roadmap

Our primary database and encrypted cloud storage infrastructure are currently operated via Supabase running on Amazon Web Services (AWS) in the United States (Region: us-east-1) during our initial Genesis beta.

For cross-border data transfers originating from the European Economic Area (EEA), United Kingdom, or Switzerland:

6. United States Privacy Rights (California CCPA/CPRA, Virginia, Colorado, Connecticut, Utah, Texas, etc.)

Notice at Collection for US Consumers

Under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and comprehensive privacy statutes in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and other states, residents have specific statutory rights regarding their personal information.

7. European Union & United Kingdom Rights (GDPR / UK GDPR)

If you are an individual located in the European Union, European Economic Area, or United Kingdom, you have comprehensive rights under Articles 15–22 of Regulation (EU) 2016/679 (GDPR) and the UK Data Protection Act 2018:

8. Canada (PIPEDA & Quebec Law 25)

For Canadian residents, our practices comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial legislation in Quebec, Alberta, and British Columbia. We collect personal information solely on the basis of meaningful consent and contractual necessity, maintain industry-standard security safeguards, and respect your rights to access and challenge compliance through privacy@layx.app or the Office of the Privacy Commissioner of Canada (OPC).

9. Australia (Privacy Act 1988 & APPs)

For Australian users, we adhere to the 13 Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth). We do not collect sensitive health or biometric information, we implement cryptographic safeguards for overseas disclosures, and you may lodge inquiries or complaints directly with us or the Office of the Australian Information Commissioner (OAIC).

10. Switzerland (revFADP)

Swiss users enjoy rights equivalent to the revised Federal Act on Data Protection (revFADP), with recourse to the Federal Data Protection and Information Commissioner (FDPIC).

11. In-App Account & Complete Data Deletion (Apple Guideline 5.1.1(v) & Google Play)

In compliance with Apple App Store Review Guideline 5.1.1(v) and Google Play Developer Policies:

12. Safety, Abuse Reporting & Human Moderation

To protect the community while maintaining E2EE integrity:

13. Children’s Privacy (Strict 18+ Rule)

LAYX is strictly intended for individuals who are at least 18 years of age (or the legal age of majority in their jurisdiction). We do not knowingly solicit, collect, or process information from children under 13 (complying with the US COPPA), minors under 16 (complying with GDPR and CCPA), or underage individuals under the UK Age Appropriate Design Code. If we discover that an account belongs to a minor, we will immediately terminate the account and purge all associated data.

14. Changes to This Policy

If we make material changes to this Privacy Policy, we will notify you through an in-app notice and update the “Effective Date” at the top of this document. Continued use of LAYX following the effective date of an updated policy constitutes acceptance of the changes.

15. Contact & Data Protection Requests

For all privacy inquiries, data subject access requests, or regulatory communications:

Email: privacy@layx.app
Entity: Three Guys s.r.o. (Attn: Legal & Privacy Team)
Jurisdiction: Slovak Republic, European Union