Privacy Policy

This Privacy Policy explains what personal data Fenan collects when you use Fenan, why we collect it, who receives it, how long we keep it, and the rights you have over it. It forms part of our Terms of Service, and words capitalised here (such as "Service", "Account", "Content", "Input", "Output", "App" and "Hosting") have the meaning the Terms give them.

This Policy and our Terms. This Policy informs you; it does not ask for your agreement or consent to processing, and it does not limit any right that data protection law gives you. The sections of the Terms on disclaimers, limitation of liability, indemnification, individual claims and dispute resolution apply to any claim about this Policy or about personal data, to the fullest extent the law allows. Where this Policy and the Terms differ about how we handle personal data, this Policy governs. Nothing in this Policy gives you rights beyond those it states and those the law gives you.

In short: we use your data to run the Service you asked for. We do not sell it, we do not build advertising profiles, we use no advertising or tracking cookies, we count page visits only if you allow it, Fenan does not train AI models on your Content, and our AI providers process it under the terms section 4 describes. What you write is processed by third-party AI providers to produce answers and Apps, so keep passwords, keys and other people’s personal data out of your chats. Your chats are stored encrypted, and our staff tools cannot read them (section 9). For the data inside your Apps, you are in charge and we act on your behalf. You can delete your Account, and everything in it, yourself in Settings. Questions go to hello@fenan.dev.

1. Who we are and what this covers

Fenan ("Fenan", "we", "us" or "our") provides the Service, an AI that plans, builds, previews and hosts web apps from a chat. This Policy covers the personal data we process about people who visit our website, sign in, hold an Account, pay for a plan, or write to us.

Fenan as controller. For your Account, your Content, your billing and your use of the Service, Fenan is the controller (in Indonesian law, the Personal Data Controller): we decide why and how that data is processed, and this Policy describes it.

Fenan as processor for your Apps. Your Apps may collect personal data of their own visitors and users, such as the accounts they sign up for, the bookings or records they enter, and the errors their visits cause. For that data, you, as the owner of the App, are the controller, and Fenan acts only as your processor (in Indonesian law, the Personal Data Processor). We process it on your instructions, which you give by using the Service, as section 5 and our Terms describe. You must give the visitors of your App your own privacy notice and answer their requests; this Policy is not that notice.

This Policy does not cover websites or services of others, including those you reach through a link in the Service or through an App, and it does not cover how Google or GitHub handle the data you give them directly. Their own policies apply.

2. Data we collect

We collect only what the Service needs. Most of it you give us directly; some we generate as you use the Service; a little comes from the partners you choose to use.

• Account data. When you sign in with Google, Google gives us your name, email address and profile picture, and an Account is created from them. We keep a record of your Account, when it was created, and its status, including any suspension and staff role.
• Content. Everything you give the Service and everything it produces for you: prompts and messages, your answers to its questions, plan approvals, elements you pick in a preview, comments on code, and the files you attach (pictures, documents and archives such as a zip of an app). If you use dictation, the recording of your voice is sent for transcription and the text is placed in your message box; we do not keep the recording, and the text becomes part of your Content only if you send it. Output includes answers, plans, code, App summaries, pictures, transcripts and error reports.
• Apps and builds. For each App: its name and address, its private source-code repository, the record of every build (the activity feed of what ran and what was written, the transcript of the build, the files it brought in), and the status of its preview and Hosting. Once you publish, each App also has its own database and file storage, which hold the data your App and its visitors put there (see section 5).
• Organisation and preferences. Projects, favorites, archived chats, chat titles, ratings you give replies, and your settings: appearance, accent color, dictation, and the personalization you choose to give (a nickname, your occupation, more about you that you choose to write, such as your interests or preferences, and instructions for how Fenan should answer).
• Billing data. Your plan, your credit balance and every movement of Credits (grants, spending by builds, pictures and searches, refunds, and any Credits we add), and, from our payment partner, the identifiers of your customer record and subscription, and the status, amount, currency and date of each transaction and invoice. We never receive or store your card number or other payment card details; the payment partner collects them directly.
• Usage data. For every call the Service makes to an AI model: the time, the kind of work (for example a reply, a plan, a build step, a picture or a search), the amount of text processed, and its cost. We use it for billing, limits, fraud prevention and to keep the Service affordable.
• Technical data. When you use the Service, our servers and providers record technical information such as your IP address, browser and device type, the pages and functions requested, times, and errors. We use it to deliver pages, keep sessions secure and investigate faults and abuse.
• Cookies and local storage. The small pieces of data your browser keeps for the Service, listed in full in section 7.
• Communications. What you write to us by email or through the Service, and our replies.
• Reports. When anyone reports an App through the Service, what they write about it and, if they give it, their email address.
• Beta access. While access to the Service is gated, the access code you enter, which your browser remembers (section 7).

We do not ask for sensitive data, such as health, biometric, religious, political or financial account data, and you should not give it to the Service. If you choose to put it in your Content anyway, you do so deliberately and, where the law requires explicit consent, that choice is your explicit consent to our processing it as part of your Content to provide the Service; you can withdraw it by deleting that Content.

3. How we use data

We use personal data to:

• provide and operate the Service and your Account, including signing you in, storing your chats and files, and showing your history;
• generate answers, questions, plans, code, pictures and transcripts with AI, and search the web or read pages when you ask;
• build, check, repair, preview and host your Apps, including reading the errors an App records so that a later build can fix them;
• charge for plans, keep your credit balance, enforce limits and prevent fraud and abuse of Credits;
• keep the Service, our users and the public safe, investigate security incidents and misuse, and enforce our Terms;
• answer your requests and provide support;
• measure and improve the Service, using aggregated or de-identified data wherever that is enough;
• comply with the law, including tax and accounting obligations, and respond to lawful requests from authorities;
• communicate with you about the Service, your Account, your plan, security and changes to our terms.

We say plainly what we do not do:

• We do not sell your personal data, and we do not share it for cross-context behavioural advertising.
• We do not build advertising profiles and show no advertising.
• We use no advertising cookies or trackers, and analytics only with your consent. If you allow it, a web analytics provider counts the pages you visit, the site that sent you, and your browser, operating system, device type and country, and how fast our pages load for you. It sets no cookies, does not store your IP address and does not follow you across other sites. You can decline, and withdraw your consent at any time, through Cookie settings at the foot of our pages or Settings → Data controls.
• Fenan does not train AI models on your Content, and trains no models at all. We send your Content to our AI providers only to produce your Output. Before a request reaches a provider that may keep what it receives, we take out text in the form of a known key or secret, which cannot catch every secret (section 4); data about other people, such as your App’s visitors’ error records, goes only to providers that keep none of it once they have answered (zero data retention); what the others may keep or learn from the rest is governed by their terms, which section 4 explains.
• We make no decision that has legal or similarly significant effects on you solely by automated means. Automatic checks, such as stopping a build when your Credits run out, apply the Terms you agreed to, and you can always write to us for a human review.

4. AI processing

The Service works by sending your Input to AI models run by third-party providers, which we reach through a model-routing service. Depending on what you ask, they receive your messages and the earlier messages of the chat, the files you attach, dictation recordings, your personalization, and the code and summary of your App, and, for a published App, the error records it has kept, which may contain data about its visitors (section 5). When you ask Fenan to search the web or read a page, a web search and page-reading provider receives the search query or the address of the page.

These providers process that data to produce the Output, under their own terms. We do not control these providers: what a provider may keep or learn from what it receives is governed by its terms, and where its terms do not limit that, it may keep and use what it receives as those terms allow. We tell you here which categories of provider receive your data, and we update this Policy when that changes. We send each provider what we judge the task needs, which can include the whole chat and the code of your App.

Do not put passwords, keys, tokens or other secrets into a chat, and do not put anyone else’s personal data into a chat unless you have a lawful basis to do so. Anything you write may be sent to these providers and kept in your chat history. When what you type or paste into the message box looks like a key, the Service notices it in your browser before the message is sent, and sends nothing until you save the key under Keys on your App’s page (section 5), keep only its name, or remove it. It recognises keys by their form, so it can miss a password or a key of an unusual form. The code Fenan writes for your App is produced in a workspace that never receives your App’s secrets or the address of its database.

Safety checks. Every plan, and every picture you attach together with the message it came with, is checked by an automated AI classifier for content that breaks our Terms before anything is built or answered. A plan it finds in the most serious categories is not built, and every plan it flags reaches our staff as a notice, together with the request that led to it, although staff tools cannot otherwise read chats (section 9). A picture it finds sexually abusive, in particular of a child, is withheld: nobody can open, use or delete it any longer, and it is kept to be handed to the competent authorities.

Output is generated by AI and can be wrong, incomplete or out of date, including about people. If Output contains inaccurate personal data about you, write to us and we will correct or remove it where we can.

5. Your Apps and their visitors

Nothing of an App is published until you press Publish. Before that, its code lives in its private repository and it runs only in a temporary preview in its workspace. The preview opens only for you, through the Service, even for someone who has its address; if you open the preview of a phone App by scanning its code, anyone who scans that code can open the preview while it runs. Once published, an App has its own database and its own file storage, and it runs at an address under Fenan’s apps domain. The data your App collects from its visitors lives there.

Every published App records its own server errors, browser errors and failed requests, with their technical details, in its own database, so that a later build can read them and repair the App, which means they are sent to the AI model providers of section 4 when you ask for a build; you must tell your visitors this in your privacy notice. These records may contain data about your App’s visitors, such as what they typed or the page they were on. They are cleared each time you publish the App again. Errors of an App that is not published stay in its temporary preview.

Every published App also counts its own visits in its own database, by page and day, with nothing about who visited, and keeps the counts for 90 days. You see them on the App’s page, and we use them, with the App’s database activity, to tell whether anyone has used the App, as section 6 of the Terms describes. Visits from inside the Service are not counted.

For your App’s data we act only on your instructions: to store and serve it, to keep it secure, to build, repair and change your App when you ask, and to delete it when the App is deleted at your request or your Account ends. We look at an App’s data only when that is needed to run the Service, to investigate abuse, a security incident or a complaint about the App, or to comply with the law.

Our processing terms. This section, together with section 6 of the Terms, is the data processing agreement between you and us for your App’s data. We process it only on your documented instructions, which you give by using the Service, and as the law requires; we keep it confidential and allow access to it only to people bound to keep it confidential; we protect it with the measures in section 9; our sub-processors are the providers listed in section 6 that host, store, serve and build Apps, and we announce a new category of sub-processor in the Service or by email at least 14 days before it applies, after which you may ask us to delete your App if you object; we help you answer your visitors’ requests where you cannot do so yourself and we reasonably can; and we delete your App’s data when the App is deleted or your Account ends, except what the law requires us to keep. By publishing an App you instruct us to keep its error records so that later builds can repair it, and to send them to AI model providers when you ask for a build. You decide what your App collects, logs and shows.

When we look at App data to investigate abuse, a security incident or a complaint, or to comply with the law, we act as a controller for that purpose alone, on our legitimate interest in keeping the Service safe and lawful or on our legal obligation, and we look only at what that purpose needs.

You are responsible for your App’s compliance with privacy law: having a lawful basis for the data it collects, publishing your own privacy notice, answering your visitors’ requests, and deleting data you have no right to keep. Visitors of an App should contact the owner of the App, not Fenan. If you are a visitor and cannot reach the owner, write to us at hello@fenan.dev naming the App’s address, and we will forward your request to the owner; we do not disclose the owner’s identity unless the law requires it, and we act on the request ourselves only where the law requires.

Because published Apps run at addresses under our domain, we and our hosting provider record technical data about requests to them (IP address, time, page requested, errors) to operate and secure the Service. We are the controller of that technical data and keep it as section 8 describes for technical logs.

Keys of your App. When you add a key or secret to your App under Keys, such as a payment provider’s API key, we pass its value directly to our hosting provider, which keeps it as an encrypted environment variable of your App. We do not store that value, we cannot show it to you again, and we never give it to AI model providers; we keep only its name and when it was last set. The keys we create for a published App, for its database and its storage, are kept in the same place; we keep no copy of them, only a one-way fingerprint of the storage key to check it. If you paste a key into a chat, the Service offers to save it here instead (section 4).

6. Who we share data with

We share personal data only as this section describes. Most recipients below are service providers that process data on our behalf, for the purpose stated, under terms that bind them to protect it and to use it only for that purpose. Google, GitHub and our payment partner handle their part as controllers of their own, under their own terms and privacy policies, which section 14 describes.

We also disclose personal data:

• When the law requires it. To comply with a law, regulation, court order or lawful request of a public authority. Where the law allows, we tell you first.
• To protect rights and safety. Where we believe in good faith that it is necessary to enforce our Terms, to investigate fraud, abuse or security incidents, or to protect the rights, property or safety of Fenan, our users, the visitors of Apps or the public.
• In a business transfer. To a buyer, successor or Affiliate in a merger, acquisition, financing, reorganisation or sale of all or part of our business, under confidentiality terms, and on condition that it continues to protect the data as this Policy describes. We will tell you before your data becomes subject to a different privacy policy.
• At your direction. When you ask us to, for example when you copy an App to your GitHub account. A chat link you copy opens only when you are signed in as its owner; it discloses nothing to anyone else.
• In aggregated or de-identified form, which cannot reasonably be used to identify you.

7. Cookies and local storage

The Service uses only the cookies and browser storage it needs to work and to remember your choices. There are no advertising or tracking cookies, the analytics we use with your consent set none, and the support chat, also only with your consent, sets its own to keep your conversation. The complete list:

Because these are strictly necessary for the Service or only remember choices you made, we do not ask for consent to them where the law does not require it. You can delete them at any time in your browser’s settings; if you delete the sign-in cookie you are signed out, and if you delete the others the Service forgets the choice they held.

8. How long we keep data

We keep personal data only as long as we need it for the purposes in this Policy or as the law requires:

• Account data: until your Account is deleted.
• Chats and messages: until you delete them, until 30 days after you delete the App they are about, or until your Account is deleted.
• Attached files: until you delete them in your library, or until your Account is deleted; deleting a chat does not delete the files it used.
• Apps, their builds, repositories, databases and storage: until 30 days after you delete the App, which you can undo until then (section 10), or until your Account is deleted. Pausing an App for inactivity deletes nothing.
• Error records of a published App: until you publish that App again, when they are cleared.
• Usage, credit and billing records: as long as tax and accounting law requires, which in Indonesia can be up to 10 years, even after your Account is deleted.
• Technical logs: at most 90 days, after which they are deleted automatically, unless a specific incident under investigation needs them longer.
• Communications with us: as long as needed to handle your request and any follow-up, and as long as the law requires.
• Pictures withheld by the safety check: for as long as the competent authorities need them and the law requires, even after your Account is deleted.
• Safety notices (a plan the safety check flagged, a report about an App): as long as we need them to handle abuse and meet the law, even after your Account is deleted, when they are no longer linked to it.
• Bug reports: until your Account is deleted; the issue we filed from a report stays in our issue tracker as long as we need it to track the fix.

When you delete your Account in Settings, the deletion happens straight away: we end your plan, stop your builds, delete each App with its repository, database, storage, site and address, delete your chats and files, and then delete the Account. What outlives it is only what this section keeps after an Account is deleted: usage, credit and billing records and safety notices, no longer linked to your Account, pictures withheld by the safety check, and a message telling our staff that the Account, named by its email address, was deleted. A domain you bought through the Service stays registered in Fenan’s account until it expires; it is not renewed and no longer points anywhere. When your Account ends in any other way, we delete or de-identify your personal data within 30 days after it ends, except records we must keep by law or need to establish, exercise or defend legal claims, which we keep only for that purpose. Copies may remain in our backups and in those of our providers until they roll off, within 30 days. We do not restore them except to recover from an incident, and if we do, we delete the data again.

9. Security

We protect personal data with measures that include:

• encryption of data in transit between your browser, the Service and our providers;
• access rules enforced on every request, so that your chats, files and Apps are reachable only through your Account, apart from the staff access described below;
• encryption of your chats where we store them: the text of your messages, plans and questions, the titles and summaries of your chats, the records of your builds (their transcripts, activity feeds, briefs and reports), your App’s memory and your comments on code are encrypted with a key held in a secrets vault, and are opened only for you, through your Account, and for the Service itself, to answer, plan and build; whoever operates the database and holds that key can technically decrypt them, and the files you attach are protected by our storage provider’s own encryption, not by this key;
• a private repository and separate database, storage and address for every published App;
• a workspace for each App, shared by its builds and its preview and separate from every other App, which never receives your App’s secrets or the address of its database, and in which only Fenan, not the AI, commits code;
• a preview that opens only for you until you publish, apart from the phone code described in section 5;
• App secrets kept only in the hosting environment of that App, never in our own database;
• payment card details handled only by our payment partner;
• staff access limited to the people and the data their task needs, as described below.

Staff access. A small number of Fenan staff use an internal panel to provide support, handle billing and prevent abuse. For each Account it shows its status, sign-ins, usage and costs, transactions and credit balance, its Apps and builds and their status, how many chats and messages it has, the bug reports it sends and the errors its published Apps record. The panel, its read-only database queries and its assistant cannot read your chats: they see only that chats and messages exist. A plan the safety check flags is the exception, and reaches staff as a notice with the request that led to it (section 4). Staff can suspend and restore Accounts and delete an Account that has no Apps. Because Fenan runs the accounts that hold your Apps’ code, your files and your published Apps, the people who operate Fenan can technically reach those, and whoever operates the database and holds its key could decrypt your chats. Staff look at your Content or an App’s data only when that is needed to provide support you ask for, to investigate abuse, a security incident or a complaint, or to comply with the law, and only to the extent needed.

No system is perfectly secure, and we cannot guarantee that personal data will never be accessed, disclosed, changed or lost by a breach of our measures. If a breach of personal data affects you, we will notify you and the competent authorities as and when the law requires.

To report a security vulnerability, write to hello@fenan.dev. Please give us a reasonable time to fix it before you disclose it, and do not access data that is not yours, degrade the Service or test against Apps you do not own.

10. Your rights and choices

Depending on where you live, you have some or all of the following rights over your personal data. Many you can use yourself in the Service; for the rest, write to us.

• Access and export. You can see your chats, files and Apps in the Service, and export your chats as a file in Settings, under Data controls. You may ask us for a copy of the personal data we hold about you.
• Correction. Your name, email address and picture come from your Google account; change them there and they update the next time you sign in. Your personalization can be changed in Settings. For anything else, write to us.
• Deletion. You can delete chats, all chats at once, and the files you attached (in your library) in the Service. You can delete your Account yourself in Settings, under Account: it deletes your Apps, chats and files at once, as section 8 describes, and cannot be undone. You can delete an App yourself on its page: it goes offline at once and, with every chat about it, rests in Recently deleted, in Settings, for 30 days, during which you can restore it, unpublished; after that its repository, database, storage, address and chats are deleted for good, and a domain bought for it is no longer renewed. Deleting an App takes it offline for its visitors and, after those 30 days, removes its data, so export or copy what you want to keep first.
• Restriction and objection. You may ask us to limit how we use your data, and object to processing based on our legitimate interests.
• Portability. You may ask for the data you gave us in a structured, commonly used and machine-readable format.
• Withdrawing consent. Where we rely on your consent, you may withdraw it at any time, for example by turning dictation off or disconnecting GitHub. This does not affect processing that took place before.
• Complaint. You may complain to the data protection authority where you live or work. We would appreciate the chance to address your concern first.

European Economic Area, United Kingdom and Switzerland. You have the rights above under the GDPR, the UK GDPR and Swiss law, including the right to object at any time to processing for direct marketing and the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. Our legal bases are set out in section 11. We are not established in the EEA or the United Kingdom; write to us directly at hello@fenan.dev and we will answer as the GDPR and the UK GDPR require.

California. In the last 12 months we have collected the following categories of personal information, for the purposes in section 3 and from the sources in section 2: identifiers (name, email address, IP address, account identifiers); customer records and commercial information (plan, purchases, credit movements); internet or other electronic network activity (use of the Service, technical logs); audio information (dictation recordings, if you use dictation); professional information (occupation, if you give it in personalization); and the Content you provide. We disclose them for business purposes to the categories of service providers in section 6. We do not sell or share personal information as those terms are defined in California law, and we have no actual knowledge of selling or sharing personal information of anyone under 16. We do not use or disclose sensitive personal information beyond what California law permits without a right to limit. You have the right to know, to delete, to correct, and to opt out of sale or sharing, and we will not discriminate against you for using these rights. You may use an authorised agent, who must give us your signed permission, and we may ask you to confirm your identity with us directly. Because we do not sell or share personal information, an opt-out preference signal such as Global Privacy Control has nothing to switch off, and we treat it as confirmed. We do not change how the Service behaves in response to Do Not Track signals, because we do not track you across other sites.

Indonesia. Under Law No. 27 of 2022 on Personal Data Protection you have the right to obtain information about the processing of your data, to complete, update and correct it, to access and obtain a copy of it, to end its processing and have it deleted or destroyed, to withdraw your consent, to object to decisions based solely on automated processing, to delay or restrict its processing, to obtain and use your data and have it sent to another controller, and, where that law provides, to claim compensation for a breach of that law in the processing of your data. You exercise these rights as that law provides, and section 18 of our Terms (dispute resolution) applies to any claim about this Policy to the extent the law allows it to. Where that law sets a shorter period than this section gives, it applies: we give you access to your data, and correct it, within 3×24 hours of a request we can verify.

How to make a request. Write to hello@fenan.dev from the email address of your Account, and say which right you want to use. We may need to confirm your identity before we act, and we will not act on a request we cannot verify. We answer within 30 days, or sooner where the law that applies to you sets a shorter period, and we will tell you if we need more time where the law allows it. Making a request is free, but we may refuse, or charge a reasonable fee for, requests that are manifestly unfounded or excessive where the law allows. We may decline a request where the law allows us to, for example to keep records we must keep or to protect the rights of others, and we will tell you why.

11. Legal bases for processing

Where the GDPR, the UK GDPR, Indonesian law or a similar law applies, we rely on the following legal bases:

12. International transfers

Fenan is operated from the Republic of Indonesia, and our service providers process data in the United States and in other countries. Those countries may not have the same data protection laws as the country where you live.

When we transfer personal data across borders, we do so as the law that applies requires: to countries recognised as providing an adequate level of protection, under contracts that bind the recipient to protect the data, including the standard contractual clauses approved by the European Commission or the United Kingdom where they apply, or on another basis the law allows. For transfers out of Indonesia, we ensure that the recipient provides a level of protection equal to or higher than Indonesian law, or that adequate and binding safeguards are in place, or, failing both, we ask for your consent. You may ask us for more information about the safeguards we use.

13. Children

The Service is only for people who are 18 or older, and we do not knowingly collect personal data of anyone under 18. If you believe that someone under 18 has given us personal data, write to hello@fenan.dev and we will delete it and close the Account.

If your App is meant for children or may be used by them, you alone are responsible for meeting the laws that protect children’s data, including obtaining any parental consent they require.

14. Third-party links and services

The Service may link to or let you connect websites and services we do not control, such as Google, GitHub, the checkout and billing portal of our payment partner, pages Fenan reads for you, and Apps made by other users. When you use them, their own terms and privacy policies apply, and we are not responsible for how they handle your data. Read their policies before you give them personal data.

15. Changes to this Policy

We may change this Policy. The effective date at the top shows when it last changed. We will announce a material change in the Service or by email before it applies, and at least 14 days before where it reduces your rights or changes how we use data you have already given us, unless the law requires it to apply sooner. Where the law requires your consent to a change, we will ask for it. If you do not agree to a change, stop using the Service; you can delete your Account in Settings. This Policy exists in English and Bahasa Indonesia. Both are provided; if they differ, the English text prevails, as our Terms provide.

16. Contact

For any question about this Policy or your personal data, to use your rights, or to report a vulnerability, write to Fenan at hello@fenan.dev.