Privacy Policy
Information about how Lokbox processes personal data.
Last updated: 13 October 2026
1. Introduction and Data Controller
This Privacy Policy explains how Lokbox processes personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR). Lokbox is an offering of Kubilé IT (sole proprietorship), owner Ernesta Kubilé. Data controller: Kubilé IT, Chratzernstrasse 2b, 4803 Vordemwald, Switzerland (UID: CHE-190.821.402). Email: info@lokbox.ch / privacy@lokbox.ch.
2. Data Categories
We process personal data generated during your use of our platform: (1) Account Data: email address, name (optional), bcrypt password hash, verification status. (2) Client Data (Dossiers): client data entered by fiduciaries (name, legal name, UID, address, canton, contacts, emails, phone numbers, and specific instructions). (3) Task Data & Prompts: workspace instructions, agent execution steps (clicks, navigation paths, errors), temporary screenshots and DOM snippets, and generated results. (4) Uploaded Documents: files provided by the user for task execution (e.g., PDF invoices, receipts). (5) Payment Data: transaction records via Stripe (amount, currency, status, billing address); credit card details are processed directly by Stripe and are never stored on Lokbox infrastructure. (6) Usage & Log Data: IP addresses, session tokens, access times, server logs.
3. Purposes of Processing
Processing is carried out for contract performance (delivering the AI agent browser), billing, customer support, platform security, and compliance with legal retention obligations (e.g., Swiss Code of Obligations Art. 958f).
4. Legal Basis (GDPR)
Where GDPR applies, processing is based on: contract performance (Art. 6(1)(b) GDPR) for service delivery; legal obligation (Art. 6(1)(c) GDPR) for accounting retention; legitimate interest (Art. 6(1)(f) GDPR) for platform security and error monitoring; consent (Art. 6(1)(a) GDPR) for user-initiated OAuth integrations.
5. Subprocessors and Locations
We engage the following partners to deliver our infrastructure: Infomaniak Network SA (Switzerland) — frontend hosting and agent backend runtime infrastructure; the servers are located in Zurich, Switzerland. Supabase, Inc. (data center Zurich, Switzerland) — Postgres database, authentication, and secure object storage. Amazon Web Services EMEA SARL (Luxembourg/EU) — Bedrock inference platform. For current Claude processing, Lokbox uses AWS Bedrock's EU geographic inference profile with Frankfurt as the primary source Region. AWS may process requests in the European destination Regions documented for that profile. For the current Claude processing path through Amazon Bedrock, AWS states that model providers do not have access to customer prompts or completions. Any retention by AWS depends on the configured Bedrock data-retention mode and AWS's documented exceptions. Google Cloud Vertex AI — Region: EU Member States, excluding Switzerland (Gemini: europe-west4, Netherlands; Claude: EU multi-region, announced). Purpose: Resolver and answer synthesis with Gemini models. Gemini: optional, only when enabled; not active by default at present. Anthropic Claude via Vertex AI: announced, not yet active. Stripe Payments Europe, Ltd. (Ireland/EU) — payment processing. Plus Five Five, Inc. (Resend) — Region: USA; sending via the EU region (Ireland) according to the account configuration, account and main processing in the USA. Purpose: Account, billing and workspace notifications (verification, password reset, invitations, document requests, digests). Sentry (Functional Software, Inc., EU region) — server-side application error monitoring.
6. International Transfers
For current Claude processing, Lokbox uses AWS Bedrock's EU geographic inference profile with Frankfurt as the primary source Region. AWS may process requests in the European destination Regions documented for that profile. For the current Claude processing path through Amazon Bedrock, AWS states that model providers do not have access to customer prompts or completions. Any retention by AWS depends on the configured Bedrock data-retention mode and AWS's documented exceptions. Google Cloud Vertex AI — Region: EU Member States, excluding Switzerland (Gemini: europe-west4, Netherlands; Claude: EU multi-region, announced). Gemini: optional, only when enabled; not active by default at present. Anthropic Claude via Vertex AI: announced, not yet active. Optional third-party integrations may transfer data to the relevant service to perform functions you initiate. Customer data is stored in Switzerland (Zurich). AI processing may take place outside Switzerland.
7. Data Security and Isolation
Workspace separation: each workspace is enforced server-side and monitored by CI checks; additional database policies are in progress. Credential Protection: OAuth tokens and API keys are stored encrypted using AES-256-GCM; credentials/2FA codes entered via the live view are encrypted in transit and never stored permanently. Model Training: we never use your data to train third-party AI models. PII Redaction: a system for automatic redaction of personal data (PII redaction) is currently rolling out (in testing phase) and is not yet active by default.
8. Retention
Account deletion first deactivates the user account and owned workspaces; it does not immediately erase every record. Memory conversation turns are soft-deleted and scheduled for hard deletion after a 30-day grace period. Billing records and other records required for legal or audit obligations remain retained for the applicable statutory period. Current status and available options are shown in the workspace settings.
9. Your Rights and Complaint Body
You have the right to access, rectify, erase, restrict, and object to the processing of your data. Contact privacy@lokbox.ch. You may lodge a complaint with a supervisory authority: in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC), Bern; in the EU, the competent supervisory authority of your residence.