1. About this notice
Devise Labs Ltd ("we", "us" or "our") is the controller of personal information handled to provide Podda, except where another organisation explains that it is acting as a separate controller. Devise Labs Ltd is registered in England and Wales under company number 17105170 at 128 City Road, London, EC1V 2NX.
This notice describes what we collect, why we use it, who receives it, how long we keep it and the choices available to you. Contact legal@podda.app with questions or requests.
2. Information we handle
Account and membership information
We process your account identifier, verified email address and the profile fields displayed in Podda. We use this information to identify app owners and members, manage invitations and enforce app boundaries.
App and content information
We handle app names and descriptions, generated code and immutable versions, key/value state, files, member-created records, network grants, app identifiers and limited logs. Content is available according to the access mode chosen by the app owner. Invite-only and link apps require signed-in membership. If an owner separately confirms public access, anyone with the app's URL can open it without signing in, and anonymous guests can read and change its shared app data and files. Content may also be disclosed when an owner authorises an external connection or disclosure is required by law.
AI and connected-service information
When you ask an assistant or Podda AI capability to create or modify an app, the relevant prompt, context and output are processed to perform that request. An app may send information to an exact external HTTPS origin only after its owner approves the connection. That external provider then handles the information under its own privacy terms.
Technical, security and support information
We process technical, usage, security and diagnostic information generated when you interact with Podda, including through supported agent and MCP interfaces. We use this information to operate, secure, diagnose and improve the service, and apply safeguards intended to limit unnecessary personal information and protect secrets.
If you contact us, we handle your email address, correspondence, identifiers you provide and the steps taken to answer or investigate the request. Do not attach or retransmit illegal content when reporting it.
Payment information
Stripe and Link process checkout, payment method, billing, tax, receipt, refund and dispute information. We receive the transaction and entitlement details needed to provide Podda, but not full payment-card details.
Cookie-consent information
To apply the privacy choices relevant to your location, Podda uses the country and, where available, region supplied by our delivery infrastructure. We store a random browser-scoped identifier, the categories allowed or denied, the applicable policy version and timestamps. If you are signed in after submitting a privacy choice, we link that privacy-choice identifier to your Podda account so that we can recognise and honour the latest linked choice when you use authenticated Podda services. This link is held within our self-hosted privacy-choice service and does not by itself enable Analytics or Marketing. See our Cookie Notice.
3. Why we use information and our legal bases
We use account, membership and app information to enter into and perform our contract with you: creating your account, providing apps, applying owner-selected access controls, saving content and responding to service requests.
We use limited technical and security information for our legitimate interests in securing Podda, preventing abuse, debugging faults, measuring reliability, enforcing our terms and keeping proportionate evidence. We balance those interests against your privacy and minimise or pseudonymise data where practicable.
We use information where necessary to comply with legal duties, including consumer, tax, accounting, data-protection, online-safety, copyright and lawful reporting obligations.
Where applicable law requires consent, including before using non-essential storage or advertising pixels, we rely on consent. Where prior consent is not required, optional technologies may operate subject to applicable notice, objection and opt-out rights. You may change your Cookie Settings at any time. Withdrawing consent does not affect processing that was lawful before withdrawal.
We link a submitted privacy choice to a signed-in account where necessary to administer, evidence and apply that choice consistently in authenticated Podda services. The linked choice determines whether account identity may be used for Analytics.
We may use contact details to send essential service, legal, security and subscription messages because they are necessary for the service or our legal obligations. We will not treat acceptance of the Terms or cookie choices as consent to marketing email.
4. Advertising and direct marketing
Podda provides separate Analytics and Marketing categories. In the EEA, United Kingdom and Quebec, these technologies remain blocked unless you allow the relevant category. In California, they are active by default unless you turn them off or we receive an applicable Global Privacy Control signal. In other locations covered by our current no-banner policy, they are active by default.
When Analytics is active, we use information about visits and use of Podda to understand performance and improve the service. We also process service telemetry and diagnostics generated when Podda handles authenticated and agent-facing interactions, including MCP, to operate, diagnose and improve the service. We associate Analytics with your Podda account only where the latest applicable privacy choice permits; otherwise relevant telemetry is handled using a temporary identifier. We do not use your name or email as the analytics identifier. You can email legal@podda.app to object, and we honour the Global Privacy Control signal where your browser sends it. When Marketing is active, we use limited visit, signup and purchase-conversion information to measure campaigns and create advertising audiences. Meta and TikTok may receive this information as advertising recipients.
We will not use private apps, files, prompts, generated code, member activity, connected-service payloads, credentials or inferred sensitive traits for advertising. We will not target children or build audiences based on health, sexuality, religion, politics, financial distress, precise location or vulnerability.
We do not sell personal information for money. Some laws define disclosure for cross-context behavioural advertising as a "sale" or "sharing" even without payment. If we introduce such processing, we will provide the notices and opt-out mechanisms those laws require, including support for Global Privacy Control where applicable.
5. Who receives information
Our current infrastructure providers are listed on the Subprocessors page.
The privacy-choice service runs within our infrastructure; no external consent-management provider receives Podda choice records.
An owner-approved external origin is chosen by the owner, not appointed by us as a general Podda subprocessor. Review that provider before sending information.
We may disclose limited information to professional advisers, insurers, auditors, regulators, courts, law enforcement or emergency services where reasonably necessary and lawful. We may also disclose information as part of a corporate transaction subject to appropriate confidentiality and notice.
6. International transfers
We are based in the United Kingdom and design Podda infrastructure to use European placement where available. Some providers or their support teams may process information outside your country.
Where UK or other applicable data-protection law restricts a transfer, we use an adequacy regulation, approved contractual safeguards or another lawful mechanism and assess supplementary protections where required. You may ask for more information about relevant safeguards.
7. How long we keep information
Our key retention defaults are:
- active account and app content while the account or app remains active;
- operational and app/network logs for seven days;
- invitation tokens for 24 hours and unused invitation contact data for 30 days after expiry;
- current privacy choice until expiry or replacement, and superseded consent evidence for three years; where a privacy choice is linked to an account, we retain and delete that link on the same basis;
- closed support, safety and privacy correspondence for three years; and
- required acceptance, copyright, deletion, transaction and accounting evidence for up to six years, subject to legal holds.
Verified deletion removes access immediately, targets live-system deletion within 30 days and allows provider backups to expire within 35 days.
When we terminate an account, access ends on the effective termination date. We target deletion from live systems within 30 days after that date and from provider backups within 35 days, except where law, security, fraud prevention, dispute resolution or evidence preservation requires limited retention.
8. Security
Podda uses named membership, signed sessions, isolated app state, private object storage, immutable code versions, default-deny external access, exact-origin grants, restricted credentials and redacted logs. Keep your account secure, minimise the information you store and report suspected compromise promptly.
9. Your rights and choices
Depending on where you live, you may have rights to access, correct, delete, restrict or object to processing, receive a portable copy, withdraw consent, opt out of targeted advertising, and complain to a regulator. You may also have the right not to receive discriminatory treatment for exercising a privacy right.
Email legal@podda.app. We may need to verify your identity and authority. We will respond within the period required by applicable law. If we cannot fulfil a request, we will explain why and tell you about available appeal or complaint routes.
Privacy choices begin as browser-scoped records. If you are signed in after submitting a choice, we link that browser’s privacy-choice identifier to your Podda account. This allows Podda to recognise and honour the latest linked Analytics choice in authenticated services. If linked choices differ, the most recently recorded explicit choice controls account-linked analytics. Linking the privacy-choice record does not itself turn on Analytics or Marketing.
A request concerning a privacy choice may include its browser identifier or, where linked, your Podda account identifier. Clearing browser storage may remove the local identifier and cause Podda to ask for a choice again, but it does not by itself delete evidence already lawfully retained. Verified account deletion includes privacy-choice subjects linked to that account, except where limited retention is required by law.
You may object at any time to direct-marketing processing and unsubscribe from marketing emails.
10. Children and teenagers
Podda is for people aged 13 and over. Anyone under 18, or anyone who cannot legally agree to our Terms where they live, may use Podda only with permission from a parent or legal guardian.
We do not knowingly allow children under 13 to create accounts or provide personal information. If you believe a child under 13 has provided information, contact us so we can investigate and take appropriate action. We separately assess children's access, privacy and safety obligations under applicable law.
11. Complaints
Please contact legal@podda.app first so we can try to resolve your concern.
12. Changes to this notice
We will update the effective date and version when this notice changes. We will provide email or in-product notice before a material change where reasonably possible.
13. Contact
Devise Labs Ltd
Company number 17105170
128 City Road, London, EC1V 2NX
legal@podda.app