Data confidentiality

Privacy policy

Last updated: September 15, 2026

This Privacy Policy explains how KharonBridge collects, uses, protects, and, when necessary, shares certain personal data in connection with its website and digital products.

KharonBridge designs products dedicated to personal and professional memory management. The nature of the information entrusted to these products requires a high degree of confidentiality, discretion, and data control.

Personal data is processed in accordance with applicable regulations, in particular Regulation (EU) 2016/679 on the protection of personal data («GDPR»).

1. Purpose and Scope

The purpose of this policy is to inform users about the nature of the data that may be processed, the purposes of such processing, the technical service providers that may be involved, the terms for retaining the data, and the rights available to users.

Processing methods vary depending on the product used. Specifically, Le Carnet relies on online services necessary for the account to function and for storing content, while Mnémosyne relies primarily on local processing on the user’s Mac.

2. Data controller

The data controller is :

Kharonbridge Lda
operating the services under the trade name KharonBridge.

Contact: contact@kharonbridge.com

For processing operations for which KharonBridge determines the purposes and means, KharonBridge acts as the data controller within the meaning of the GDPR.

3. Data That May Be Processed

3.1. The KharonBridge Website and Contact Requests

When a user visits the website, contacts KharonBridge, requests information, or uses a form available on the website, certain data may be processed, including:

• last name or first name, when provided; ;
• e-mail address ;
• content of the message or request; ;
• information needed to process a support request; ;
• technical data strictly necessary for the security and operation of the site.

3.2. The Notebook

The Carnet is a personal note-taking app that allows users to record ideas, decisions, thoughts, and moments they want to be able to refer back to later.

When using Le Carnet, the following categories of data may be processed, among others:

• email address and information required to create and authenticate the account; ;
• country or location information provided by the user, when required for the service; ;
• account settings and preferences; ;
• entries written in the notebook; ;
• headings, texts, thoughts, decisions, and other content intentionally saved; ;
• additions or supplements to an existing entry; ;
• images or photographs intentionally uploaded by the user; ;
• information needed to schedule a future review; ;
• data related to time capsules, including their contents and opening dates; ;
• when a Time Capsule is intended for another person, the contact information needed to deliver it, if provided by the user; ;
• information regarding Premium status or Capsule credits; ;
• technical transaction identifiers required to validate purchases made through Apple; ;
• technical and security data necessary for the operation of the service.

Entries in the Journal are private. They are not published on a social network, are not made available to other users, and do not constitute a public content feed.

3.3. Mnemosyne

Mnémosyne is a professional memory and decision-making app designed to centralize client files, assignments, documents, working notes, and the relationships between these elements on the user’s Mac.

Under normal operating conditions, the Mnémosyne vault is stored locally on the user’s Mac. Simply installing or using the application does not, in and of itself, result in the vault’s contents being transmitted to KharonBridge.

The information that the user chooses to store in Mnémosyne may include, among other things:

• information about its customers or business contacts; ;
• business contact information; ;
• assignments and files; ;
• working notes; ;
• professional decisions and reasoning; ;
• imported documents and files; ;
• metadata, relationships, and history that help preserve the context of the work.

3.4. Payments and Purchases

KharonBridge does not directly collect credit card numbers or complete banking information used to pay for purchases made through its products.

Depending on the product and the distribution channel used, payments may be processed by Apple or by Lemon Squeezy.

For apps or features sold through the App Store or the Mac App Store—including Le Carnet subscriptions and in-app purchases, as well as purchases made through Apple platforms—transactions are processed by Apple in accordance with Apple’s terms and conditions and privacy policy.

For certain direct sales of Mnémosyne made outside the Mac App Store, payment is processed by Lemon Squeezy. Lemon Squeezy handles the processing of the transaction and the payment information necessary to complete the purchase in accordance with its own terms and conditions and its privacy policy.

KharonBridge may receive from these service providers the information necessary for managing the purchase and the rights associated with the product, such as:

• the product or offer purchased; ;
• the transaction status; ;
• the status of a subscription, if any; ;
• technical order or transaction identifiers; ;
• the information necessary to activate, manage, or verify the product's usage rights; ;
• certain billing or tax jurisdiction information when its disclosure is necessary for order processing, accounting, or compliance with applicable legal obligations.

Complete banking information, such as a full credit card number, is not stored directly by KharonBridge in connection with these transactions.

3.5. Special or Sensitive Data

KharonBridge does not require users to provide sensitive data, as defined by the GDPR, as a condition for accessing its services.

However, the open nature of the content created in Le Carnet or the professional documents stored in Mnémosyne means that a user may choose to enter or import information that could reveal sensitive data.

Users retain control over the information they voluntarily choose to store in their accounts.

4. Purposes of Data Processing

4.1. Site and Media

Data provided through the website or to customer support may be used to:

• respond to requests sent to KharonBridge; ;
• provide user support; ;
• handle technical or administrative requests; ;
• secure the site and services.

4.2. The Notebook

The data processed in Le Carnet is used to:

• create, authenticate, and manage the user account; ;
• enable the creation and storage of entries; ;
• enable users to search for, view, and follow up on previous entries; ;
• allow for the scheduling of future reviews; ;
• create, preserve, and distribute time capsules; ;
• manage Premium features; ;
• manage Time Capsule credits; ;
• enable the use of optional features such as Clara; ;
• send the transactional emails necessary for the account to function; ;
• prevent unauthorized access, misuse, fraud, and technical incidents; ;
• Ensure the maintenance, continuity, and security of the service.

4.3. Mnemosyne

Mnémosyne allows users to organize their professional knowledge locally, specifically to:

• centralize their work files; ;
• link customers, assignments, documents, and notes; ;
• preserve the context of a decision or piece of information; ;
• retrieve the saved items; ;
• maintain a timeline and the relationships between pieces of information; ;
• perform backups, exports, or restores whenever he or she wishes.

Processing performed exclusively on the user's Mac is carried out under the user's control within the user's own computing environment.

4.4. Security and Legal Obligations

Certain data may also be processed for the following purposes:

• prevent and detect security incidents; ;
• prevent fraudulent or abusive use; ;
• comply with applicable legal and regulatory requirements; ;
• respond to legally valid requests from the competent authorities; ;
• to establish, exercise, or defend KharonBridge's rights in the event of a dispute.

5. Clara and Artificial Intelligence-Based Treatment

Some KharonBridge products may offer Clara, an optional assistance feature designed to help the user review, clarify, or restore the context of a piece of information.

In Le Carnet, Clara operates on the user’s request. When a user intentionally triggers this feature on an entry, the content needed for the requested analysis is sent to the artificial intelligence service used by KharonBridge to produce the expected result.

For this feature, KharonBridge uses the OpenAI API.

Clara is neither a social network nor a standalone chat service. In Le Carnet, it responds to a post when the user requests it and provides feedback or clarification limited to the context provided.

If the user does not enable Clara for an input, that input is not sent to OpenAI as part of this feature.

Clara is not intended to make a medical or psychological diagnosis, provide therapy, or make decisions that have legal or similar consequences for the user.

The data transmitted to an artificial intelligence service provider is limited to what is necessary for the requested feature to function.

6. Legal Basis for Processing

Depending on the nature of the processing in question, KharonBridge relies on one or more of the legal bases set forth in Article 6 of the GDPR.

6.1. Performance of the Contract

The data processing required to create and manage a Le Carnet account, to provide the requested features, to manage purchases, and to perform the subscribed services are based primarily on the performance of the contract entered into with the user or on precontractual measures taken at the user’s request.

6.2. Consent

When regulations require specific consent, such consent is obtained prior to the processing in question.

The user may withdraw consent at any time for processing based on this ground, without such withdrawal affecting the lawfulness of processing carried out prior to the withdrawal.

6.3. Legitimate Interest

KharonBridge may process certain data based on its legitimate interest, in particular to:

• secure its services and infrastructure; ;
• prevent abuse, fraud, and unauthorized access; ;
• maintain the quality and technical stability of services; ;
• to ensure the protection of their rights and interests.

6.4. Legal Obligation

Certain processing activities may be necessary to comply with a legal or regulatory obligation applicable to KharonBridge.

7. Technical Service Providers and Recipients

KharonBridge does not sell, rent, or transfer users' personal data or content to third parties for commercial purposes.

However, certain data may be processed by technical service providers when their involvement is necessary for the service to function.

The main services involved include, in particular:

• Cloudflare : technical infrastructure used, in particular, for certain backend services, security features, and services necessary for the operation of Le Carnet; ;
• OpenAI : processing of transmitted content when a user explicitly requests the use of Clara; ;
• Apple : Distribute apps through the App Store or the Mac App Store; manage subscriptions and in-app purchases using StoreKit.

Depending on the services involved, these service providers may act as subcontractors of KharonBridge or as independent data controllers for the operations they themselves determine, particularly in connection with their own legal obligations.

Apart from service providers necessary for the operation of the services, data is disclosed to third parties only when required by law or when a legally valid request is received from a competent authority.

8. Data Storage and Security

8.1. The Notebook

The Carnet uses an online infrastructure necessary for account management, the storage of entries, time capsules, and the operation of related services.

KharonBridge implements technical and organizational measures designed to protect data against unauthorized access, alteration, loss, disclosure, or accidental destruction.

Depending on the components involved, these measures include, among other things, access controls, authentication mechanisms, technical logs, and measures to secure the infrastructure.

Since no computer system can guarantee absolute security, KharonBridge implements a risk-mitigation approach tailored to the nature of the data being processed.

8.2. Mnemosyne

Mnémosyne is built on a local architecture: the work folder and its contents are stored on the user's Mac.

This allows users to retain control over their folders, documents, notes, and backups within their IT environment.

In particular, Mnémosyne offers features that allow you to secure access to the application and manage the backup, export, and restoration of the vault.

The user remains responsible for the security of their Mac, their backups, and any copies or exports they create outside the app.

When a user chooses to save or copy a Mnémosyne export to a third-party service, cloud storage, or another medium, the processing performed by that third-party service is also subject to that provider’s terms and conditions.

9. Shelf Life

9.1. Site and Media Data

Data provided in connection with a contact or support request is retained for as long as necessary to process the request, and then for as long as is reasonably necessary to follow up on the request or to comply with KharonBridge’s legal obligations.

9.2. The Notebook

Data associated with the Le Carnet account and content saved by the user are retained for as long as necessary to provide the service and, in principle, for the duration of the account.

When a user deletes their account, the active data associated with the account is deleted or made permanently inaccessible in accordance with the service’s deletion process, subject to the following:

• the technical time required to carry out the deletion; ;
• applicable backup and security procedures; ;
• any legal obligations requiring the temporary retention of certain information.

Data retained solely to comply with a legal obligation or to ensure security is not used for any other purpose.

9.3. Mnemosyne

Data stored exclusively in the local Mnémosyne vault remains under the user's control. The retention period is determined by the user.

Deleting an item in Mnémosyne, deleting the vault, or uninstalling the application does not necessarily result in the deletion of any backups or exports that the user may have created separately.

9.4. Technical Specifications and Safety

Certain technical logs, security logs, or information necessary for preventing abuse may be retained for a limited period of time, proportionate to their purpose, and then deleted or anonymized.

10. International Data Transfers

KharonBridge prioritizes, when technically and economically feasible, infrastructure that offers a high level of data protection.

However, certain technical service providers used by KharonBridge, particularly for infrastructure or artificial intelligence services, may involve data processing outside the European Economic Area.

When an international transfer of personal data is subject to the GDPR, KharonBridge ensures that it is based on a legally recognized mechanism, such as an adequacy decision or appropriate safeguards provided for by applicable regulations.

11. User Rights

In accordance with the GDPR and subject to the conditions set forth in the regulations, the user has the following rights:

11.1. Right of Access

Users may inquire whether KharonBridge processes personal data about them and, where applicable, obtain access to that data.

11.2. Right to Correction

Users may request the correction of inaccurate, incomplete, or outdated personal data.

11.3. Right to Erasure

The user may request the deletion of their personal data when the conditions set forth in the regulations are met, subject to applicable legal retention obligations.

11.4. Right to Restriction of Processing

The user may request that processing be restricted in the situations provided for by the regulations.

11.5. Right to Data Portability

When this right applies, the user may receive the data they have provided to KharonBridge in a structured, commonly used, and machine-readable format.

11.6. Right to Object

The user may object to certain processing activities based on KharonBridge’s legitimate interest for reasons related to his or her particular situation, subject to the exceptions provided for by law.

11.7. Withdrawal of Consent

When processing is based on consent, that consent may be withdrawn at any time without affecting the lawfulness of the processing carried out prior to its withdrawal.

11.8. Exercising Rights

Requests regarding personal data may be directed to:

contact@kharonbridge.com

KharonBridge may request the information strictly necessary to verify the applicant's identity when such verification is warranted.

12. Data Concerning Third Parties

12.1. Recipients of Time Capsules

When a Le Carnet user creates a Time Capsule intended for another person, they may be asked to provide the information necessary to identify or contact that recipient.

The user must ensure that he or she has a legitimate reason for providing this information and that he or she provides only the data necessary for the operation of the Capsule.

12.2. Professional data stored in Mnémosyne

When a professional uses Mnémosyne to organize information related to their clients, prospects, employees, suppliers, or partners, it is their responsibility to comply with the data protection obligations applicable to their business.

In particular, the professional user remains responsible for the legal basis, for informing data subjects, for retention periods, and for ensuring that data subjects can exercise their rights regarding the data the user chooses to store locally in their Mnémosyne vault.

13. No advertising, no sale of data, and no commercial profiling

KharonBridge does not sell personal data or content uploaded by users.

The content of the Carnet and the data contained in Mnémosyne are not used to create advertising profiles.

KharonBridge does not integrate any third-party advertising networks into Le Carnet or Mnémosyne for the purpose of monetizing user data or content.

The information entrusted to KharonBridge products is used to provide, maintain, protect, and improve the features to which it relates, and not to monetize the user's attention or privacy.

14. Confidentiality and the Principle of Data Minimization

KharonBridge designs its products around personal, professional, and memory-related information that may be particularly private in nature.

KharonBridge follows a principle of data minimization: only the data necessary for a feature to function should be processed for that feature.

Technical and organizational decisions are made, to the extent applicable, in accordance with the principles of data protection by design and by default («privacy by design» and «privacy by default»).

Privacy is a core design principle of KharonBridge products, not just an afterthought.

15. Security Incidents

In the event of a personal data breach that is likely to pose a risk to the rights and freedoms of the data subjects, KharonBridge implements the necessary corrective measures and, when required by regulation, require, notifies the competent supervisory authority and/or the data subjects.

16. Changes to the Privacy Policy

This policy may be updated to reflect changes in KharonBridge products, their features, the technical service providers used, or the applicable legal framework.

The date of the last update appears at the top of the document.

When a substantial change affects the way in which personal data is processed, KharonBridge may notify users through an appropriate means, including within the service or by email, when such communication is relevant.

When regulations require new consent for data processing, such consent will be requested before the relevant data processing begins.

17. Contact and Complaints

If you have any questions regarding this policy or the processing of personal data:

contact@kharonbridge.com

The user also has the right to file a complaint with the competent data protection authority, specifically with the Comissão Nacional de Proteção de Dados (CNPD) in Portugal when it has jurisdiction.