Privacy Policy
Last updated: 29 September 2026
This policy explains what personal data Epicus collects when you use the Epicus app (at app.epicus.io and in the Epicus apps for iOS and Android) and this website (epicus.ai), why we collect it, who we share it with, how long we keep it and what your rights are. We have written it to be read, so it describes what the product actually does.
1. Who we are
The controller of your personal data is [Legal entity name, e.g. Epicus B.V.], [adres], Amsterdam, The Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number [KvK-nummer] ("Epicus", "we", "us").
For anything related to privacy, email privacy@epicus.ai.
2. What we collect
Account and sign-in data
- Your name, email address and password (stored only as a one-way hash, never in readable form).
- Optionally a profile photo, country, time zone and job role.
- Two-step verification: when you sign in we email you a one-time code. The code is stored hashed and expires after 10 minutes.
- App lock: if you turn on the PIN lock, we store a hashed PIN linked to a random device identifier. Nothing secret is stored on the device itself.
- Sign-in tokens, which expire after 14 days of use, and your app settings and notification preferences.
Organization and team data
- The organization you belong to, your role in it (for example administrator or finance contact), and the email domain your organization has verified.
- The teams you are a member of, buddy and coaching relationships you accept, and invitations you send or receive.
- Your answers to team surveys and the notes you add to them.
Coaching and development data
This is the heart of the product, and the most personal data we hold:
- Your conversations with the AI coach, including onboarding, check-ins and meditations. If you use the microphone, your voice recording is converted to text (see section 4); the recording itself is not stored.
- Notes the AI coach keeps so it can remember you between conversations: a short profile (your work context, strengths, growth areas and patterns it has noticed) and events you have told it about, such as a difficult meeting or a decision.
- Your goals, development needs, exercises and the progress you log on them, courses and lessons you follow.
- Assessments and scores: your leadership development level, skill and belief assessments, questionnaires (including a personality questionnaire) and the results derived from them.
- Reflections you write in the app, for example the worries, hidden commitments and assumptions you map during a breakthrough.
We do not ask for sensitive data such as health, religion or political views. Coaching conversations are free text, though, so you may choose to mention such things. If you do, we use them only to coach you, and you can have them deleted at any time by deleting your account (see section 8).
Payment data
When you sign up a company and pay for it, payment is handled by Stripe. We send Stripe your email address and receive back whether the payment succeeded. We never see or store your card or bank details.
Technical data
- A log of requests made to our servers (which endpoint was called, when, by which account, and the request and response content with passwords, codes and other credentials removed). We use it to find bugs, investigate abuse and keep the service secure.
- Standard server logs kept by our hosting provider.
When you contact us
If you use the contact form or send us feedback, we keep your name, email address, phone number (if you give it) and your message so we can answer.
3. Why we use it, and on what legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Creating and securing your account, signing you in, two-step verification and the app lock | Performance of our contract with you (Art. 6(1)(b)) |
| Providing AI coaching, exercises, courses, assessments and progress tracking | Performance of our contract with you (Art. 6(1)(b)) |
| Voice input in the chat (only when you tap the microphone) | Your consent, given by choosing to use the microphone (Art. 6(1)(a)) |
| Providing team features, buddies, coaching relationships and the organization dashboard | Performance of the contract, and our and your organization's legitimate interest in running its development programme (Art. 6(1)(b) and (f)) |
| Processing payments and keeping invoicing records | Performance of the contract, and our legal obligations under Dutch tax law (Art. 6(1)(b) and (c)) |
| Service emails: sign-in codes, invitations, password resets, payment reminders | Performance of the contract (Art. 6(1)(b)) |
| Request logs, error monitoring, preventing abuse and keeping the service secure | Our legitimate interest in a secure, working service (Art. 6(1)(f)) |
| Improving the product using aggregated usage statistics | Our legitimate interest in improving Epicus (Art. 6(1)(f)) |
| Answering your questions and feedback | Our legitimate interest in helping you (Art. 6(1)(f)) |
| Sensitive information you choose to mention in a coaching conversation | Your explicit consent, given by sharing it with the coach (Art. 9(2)(a)); you can withdraw it by deleting your account |
We do not sell your data, we do not use it for advertising, and the app contains no advertising or third-party tracking software.
4. How the AI coach uses your data
The coach is powered by large language models. To produce a reply, we send the relevant part of your conversation to a language model, together with context the coach needs: your first name, your goal and development need, your exercises and progress, and the profile and events the coach keeps about you. The model returns text, which we store as part of your conversation.
- We reach these models through OpenRouter, which forwards each request to the provider of the model in use. Today these are models from OpenAI (our main models), with models from Google, Anthropic and DeepSeek as fallbacks when the main model is unavailable.
- To let the coach find earlier conversations and events by meaning, the text of your messages and events is also converted into numerical representations ("embeddings") by an OpenAI model via OpenRouter. These are stored with your data in our own database.
- When you speak to the coach, the audio clip is sent to a Google Gemini model via OpenRouter to be transcribed. The transcript appears in the input box for you to check before sending. We do not store the recording.
- We use these models through their business APIs, not through consumer chat products. The model providers' API terms generally do not allow them to use API data to train their models, but some keep inputs for a limited period to detect abuse. Their own terms and privacy policies apply to that processing.
- The coach estimates your leadership development level and suggests goals and exercises. These are suggestions to support your own development. They are not used to make decisions about your employment, and no decision with legal or similarly significant effects is made about you by automated means.
5. Who can see your data
Within your organization
If you use Epicus through your employer, your employer is the customer, but your coaching is yours:
- Your organization's administrators can see the list of people in the organization: name, email, photo, country, time zone, role, whether they are an administrator, when they joined and when they last signed in. They can also remove people from the organization.
- The organization dashboard shows only aggregated figures: how many people use the app, how many exercises are active, how many coaching conversations take place, how people are spread across development levels, and team culture scores. It does not show your conversations, your notes or your individual answers.
- Colleagues in your organization can see your name, email, photo, country, time zone and role, for example when choosing a buddy.
- Your team sees team survey results as combined scores and counts. Notes you add to a team survey are shown to the team without your name.
- A human coach, only if you accept their invitation to coach you, can see your goal, development need, development profile and level, exercises, breakthrough map and how active you are (for example how many conversations you have had). A coach cannot read your conversations with the AI coach.
Service providers
We use the following processors. Each only processes data on our instructions and under a data processing agreement.
| Provider | What for | Where |
|---|---|---|
| Scaleway (France) | Hosting of the app servers, database, file storage (such as profile photos), logs and secrets | Amsterdam, the Netherlands (EU) |
| OpenRouter (USA) | Routing requests to AI models for coaching, embeddings and voice transcription | United States |
| AI model providers via OpenRouter: OpenAI, Google, Anthropic, DeepSeek | Generating coaching replies, embeddings and transcripts | Mainly the United States; other countries depending on the model and hosting provider |
| Postmark (ActiveCampaign, USA) | Sending service emails such as sign-in codes, invitations and password resets | United States |
| Stripe | Payment processing for company sign-ups | EU and United States |
| Matomo Cloud (InnoCraft) | Cookieless visitor statistics for this website only | [locatie Matomo-hosting controleren] |
| Google (Fonts, YouTube) | Loading fonts; playing embedded course videos when you open one | United States and elsewhere |
Within Epicus, access to personal data is limited to the people who need it to run, support and secure the service.
We may also disclose data where the law requires it, for example to comply with a court order.
6. International transfers
Our database, servers and file storage are hosted by Scaleway in Amsterdam, in the European Union. Some of the providers above, notably OpenRouter, the AI model providers, Stripe and Postmark, are based in or process data in the United States or other countries outside the European Economic Area. For those transfers we rely on the EU-U.S. Data Privacy Framework where the recipient is certified under it, and otherwise on the European Commission's Standard Contractual Clauses, with additional safeguards where needed. You can ask us for a copy of the relevant safeguards.
7. How long we keep it
- Your account and coaching data: for as long as you have an account. When you delete your account, it is deleted permanently (see section 8).
- Company sign-ups that are never paid for: we send reminders, and if the sign-up is still unpaid about 13 days after it was created (and at least 3 days after a final notice), the account and organization are deleted automatically.
- Request logs: 90 days, then deleted automatically.
- Sign-in codes: expire after 10 minutes. Sign-in tokens: expire after 14 days of use.
- Payment and invoicing records: 7 years, as required by Dutch tax law.
- Messages to us: as long as needed to handle your question, and no longer than [bewaartermijn contactberichten, e.g. 2 years].
- Backups: deleted data can remain in our encrypted database backups for up to [backup-bewaartermijn, e.g. 7 days] until those backups expire.
8. Your rights
Under the GDPR you have the right to:
- Access the personal data we hold about you, and receive a copy.
- Rectify data that is wrong. Most of your details can be changed in the app's settings.
- Erase your data. You can delete your account yourself, at any time, in the app under Settings → Delete account or at app.epicus.io/delete-account. This permanently deletes your account and personal data. See how to delete your account for details.
- Restrict or object to processing, including processing based on our legitimate interests.
- Data portability: receive the data you gave us in a structured, machine-readable format.
- Withdraw consent where we rely on it, without affecting processing that took place before.
To exercise any of these rights, email privacy@epicus.ai from the address linked to your account. We answer within one month. If you use Epicus through your employer, you can come to us directly; you do not need to go through your employer.
If you are unhappy with how we handle your data, please tell us first. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the supervisory authority in the EU country where you live or work.
9. Security
All traffic is encrypted (HTTPS). Passwords, sign-in codes and PINs are stored only as hashes. Sign-in requires a second factor by email, repeated failed attempts are limited, and access to production systems and secrets is restricted.
10. Cookies, analytics and device storage
- The app uses only what it needs to work: a sign-in token and your preferences, stored on your device, and session cookies that are strictly necessary for signing in. There is no analytics, advertising or tracking software in the app.
- This website uses Matomo to count visits, with cookies disabled. Matomo receives technical data such as your IP address, browser and the pages you visit, and we use it only for aggregated statistics about how the website is used.
- Fonts on this website and in the app are loaded from Google Fonts, which means your device connects to Google's servers and shares your IP address with Google.
- Videos: some course videos in the app are embedded from YouTube. They load only when you open a video, and YouTube may then set its own cookies under Google's privacy policy.
11. Children
Epicus is a leadership development service for working adults. It is not intended for anyone under 16, and we do not knowingly collect data from children. If you believe a child has given us personal data, contact us and we will delete it.
12. Changes to this policy
We will update this policy when the product or the law changes. The date at the top shows when it last changed. If a change materially affects how we use your data, we will let you know in the app or by email before it takes effect.
13. Contact
[Legal entity name, e.g. Epicus B.V.]
[adres]
KvK: [KvK-nummer]
Email: privacy@epicus.ai