This is a translation prepared using artificial intelligence. The original text is the Polish version. If the versions differ, the “Language versions” section describes how this is resolved. Polski

Privacy Policy of the “Lokavi Home” app

Version 2.2.1 – published 9 November 2026. Amends version 2.2 solely with regard to reports of AI-generated content made with the “Report” button in the App (section 2 – new row, section 5d – new paragraph, section 6 – retention period). The remaining content is unchanged. Version 2.2.1 applies from the date of publication.

The Operator's contact details were updated on 7 November 2026 (editorial change – the rest of the text is unchanged).

1. Who is responsible for the data

The “Lokavi Home” app (hereinafter: the App) is made available by Sebastian Jabłoński spółka komandytowa with its registered office in Warsaw, ul. Bonifraterska 17, 00-203 Warszawa, entered in the register of entrepreneurs of the National Court Register (KRS) under number 0000855880, NIP 5252833038, REGON 386820681 (hereinafter: the Operator). Contact regarding personal data: privacy@lokavi.pl.

The App is used to organise work in a private home: planning tasks for domestic workers, registers, reports, chat, meals and “right now” requests. Each home in the App has an administrator (the person who created it). With respect to the data of domestic workers and other persons that the home administrator enters into the App for purposes going beyond purely personal or household activities, the controller of the data within the meaning of the GDPR is the home administrator, and the Operator processes that data on the home administrator's behalf as a processor, under a data processing agreement (Annex 2 to the Terms of Service). Where the home administrator uses the App solely for personal or household purposes, the Operator applies the same rules and safeguards to that data. The Operator is the controller with respect to: account data (e-mail address, password, sign-in logs), security and logs, the balance, subscription and payments, marketing (section 5a), content reports (section 5d), and the shopping agent, reading a list from a photo or dictation and store selection for shopping list items (section 5b).

2. What data is processed

DataSourcePurpose
E-mail address, password (stored only as a hash), Apple/Google account identifier, name (if you share it; with Google usually first and last name) and Google profile photo address (stored, not used) – if used (section 2a)provided by the user when creating an account, or passed on by Apple or Google after the user consents to sign-insigning in, password recovery, assignment to a home
E-mail address of a person in the home (optional field)entered by the home administrator or coordinator (for workers, household members and themselves); when a person links an account using the “Link” button and no address has yet been entered for them, the confirmed address of their account is stored there (including an Apple relay address)recognising that an e-mail, Apple or Google account belongs to that person, and linking them (section 2a)
Name, role and position in the home, PIN (stored only as a hash)entered by the home administrator or by the user themselvessigning in with a PIN, assigning tasks
Sessions of signed-in devices: sign-in method (PIN, QR code, e-mail, Apple, Google), a short device description (e.g. “iPad · app”), time of last userecorded automatically at sign-insecurity, and enabling the administrator or the person to view and disconnect devices; a session is deleted after signing out, disconnecting the device or unlinking the account from the person, and an unused session expires after 120 days and is then deleted
Name and address of the homeentered by the home administratoridentification of the home, content of statements for workers; the address – also for the shopping agent (choice of delivery, city when searching for offers; section 5b)
Tasks, completion statuses, times, work schedule, registers (shopping, faults, laundry, items), daily reports, “right now” requests, announcements, mealsentered by the home's usersorganising work in the home
Photos taken in the App (task result, check requests, registers, chat)taken by the user, solely by their own actionquality control of work and documentation of reports – in accordance with the information notice accepted in the App
Messages in chat and in groupsentered by userscommunication within the home
Push notification token, device model, operating systemthe user's device, after the user consents to notificationssending notifications
Date and time of sign-ins, IP address, technical event logautomaticallysecurity, abuse detection, fixing errors
Orders for the shopping agent (shopping list, amount limit, the home's answers to the agent's questions, screenshots of the shop), a photo of a list or dictated text to be read by AIentered by the home's users; optional features, disabled by defaultmaking purchases at the administrator's instruction, reading the list (section 5b)
Own API key for the AI model provider (stored only encrypted on the device; in plain text only the provider name and the last 4 characters), its verification statusentered by the home administrator, if they choose their own keythe agent's work on the home's account with the model provider (section 5b)
Agent balance and transaction history: top-ups (amount, date, Stripe payment identifier, person topping up), charges for runs (model, number of tokens, amount) and refunds of those charges, starter gift, refunds of payments, Operator adjustments; identifier of the account to which the gift was grantedautomatically, from the payment confirmation from Stripe and from the results of the agent's worksettlement of the agent's work, accounting and taxes, ensuring the gift is granted only once (section 5c)
Payer and payment data (first and last name or company name, e-mail address, country of the billing address, NIP – if provided, payment method)provided by the payer on the Stripe payment pageaccepting the payment, checking whether the payment can be accepted (billing address country in the European Union, type of tax number), VAT settlement – including the record of payments from consumers from other European Union countries, invoice on request (sections 5c and 5h)
AI subscription: Stripe customer and subscription identifier, plan, status, billing periods, subscription payments and invoices, usage within the limitautomatically, from confirmations from Stripe and from the results of the agent's workperformance of the subscription contract, accounting and taxes (section 5c)
Statements made before payment (acceptance of the Terms of Service and their version, request to commence performance before the withdrawal period expires; version of the wording, person, time, payment identifier)made by the home owner in the payment windowdemonstrating conclusion of the contract and settlements, confirmation by e-mail (section 5c)
Statements of withdrawal from the contract (first and last name, e-mail address, contract, date and time of submission)provided by the home owner in the “Withdraw from the contract” window or by e-mail or letteraccepting the withdrawal, confirmation and refund (section 5c)
Content reports and appeals (reporter's data, content of the report, decision and its statement of reasons)provided by the reporter or the user by e-mailhandling reports and appeals (section 5d)
E-mail address of the home ownerthe home owner's accounttransactional e-mails about the agent balance (welcome, low balance, insufficient funds, change to billing rules)
decisions regarding marketing consents (content and version of the consent, date, source, browser, account e-mail address)given by the user in the App or on the account pagedocumenting marketing consents and being able to demonstrate them
Home scan frames (images of interiors, without frames showing people or documents), the schematic room model, an uploaded home plan, crops of items, names, places and quantities of items, text dictated about the contents of a place, who scanned and when, cost of the scantaken by the user with the phone camera or dictated; an optional function, switched on by the home administratorregister of items in the home and searching “where things are” (section 5i)
Reports of AI content in the App (“Report”): the home, the account and the reporting person, the type and identifier of the reported content (without a copy of it), the reason, a description of up to 500 characters, the statusprovided by the user with the “Report” button next to AI contentchecking AI content and improving the AI features, compliance with app store rules (section 5d)

The App does not collect location data, does not read contacts or files on the phone and does not launch the camera without user action. The App displays and sends offers and marketing information only to persons who have consented to this, and profiling for the purpose of selecting offers takes place only with consent (section 5a). Payment card data is not stored in the App – the shopping agent uses the payment method saved in the administrator's shop account, and top-ups of the agent balance and the AI subscription are handled by Stripe (card or BLIK details are entered only on the Stripe payment page).

2a. Signing in with Apple and Google

You can sign in to the App using “Sign in with Apple” or “Sign in with Google” (in the Android app – Google only). This is a convenient alternative to a password – using it is voluntary, and signing in with a PIN, a QR code or an e-mail address and password continues to work.

3. Legal bases

4. Data recipients

EntityRoleLocation
Supabase Inc.database, sign-in, photo storageservers in the European Union (Ireland)
GitHub Inc. (GitHub Pages)hosting of App files (browser version)USA – standard contractual clauses
Resend Inc.sending confirmation and password reset e-mails, transactional e-mails about the agent balance, and confirmations of payment and of withdrawal from the contract (sender agent@send.lokavi.pl) – receives the recipient's e-mail address, the home name, the balance, payment or withdrawal data and a link to the Appservers in the European Union
Stripe Payments Europe, Limitedpayment operator for agent balance top-ups and the AI subscription (card, BLIK, Link); also processes payer and payment data as a separate controller, in accordance with its own privacy policy (stripe.com/pl/privacy)Ireland (EU); transfer to Stripe, Inc. in the USA – adequacy decision (DPF) / standard contractual clauses
Apple Inc. / Google LLCdelivery of push notifications; in addition, when signing in with Apple or Google (if used), they act as separate controllers of their own sign-in service (section 2a)USA – standard contractual clauses / adequacy decision (DPF)
Anthropic PBCAI model for the shopping agent, list reading and store selection: with “our tokens” billing and for list reading – as the Operator's processor; with the home's own API key, if the home has chosen this provider – on the terms of the home's agreement with the provider (section 5b); store selection for shopping list items (item name and quantity, the home's stores and shopping preference) – always as the Operator's processor, on the Operator's account, also in a home with its own API key, including where that home's agent uses another provider (OpenAI or xAI) (section 5b); translation of content entered in the home, where it is enabled (section 5e) – as the Operator's processor, and with respect to data for which the home administrator is the controller – as a further processor; home scan, where it is switched on (section 5i) – as the Operator's processor, and with respect to data for which the home administrator is the controller – as a further processor; virtual AI manager, where the home administrator switches it on (section 5j) – on the Operator's account, also in a home with its own API key, as the Operator's processor, and with respect to data for which the home administrator is the controller – as a further processorUSA – standard contractual clauses (Article 46(2)(c) GDPR)
OpenAI (OpenAI OpCo, LLC) and xAI (X.AI LLC)AI model for the shopping agent, only with the home's own API key, where the home has chosen this provider; the data goes to the provider on the terms of the agreement the home has concluded with the provider (section 5b)USA – according to the home's agreement with the provider (standard contractual clauses or adequacy decision – EU-US Data Privacy Framework)
OVHcloud (OVH group)shopping agent server: browser opening shops, screenshots taken during shopping, decryption of shop passwords and the API key for the duration of a run (section 5b)Poland (Warsaw), European Union
SerpApi, LLCoffer search engine (Google Shopping) when the agent searches for and compares offers – receives the name of the product searched for and the home's city, without data about individuals (section 5b)USA – the information transferred (product name and city) does not make it possible to identify a person, so it is not personal data

A copy of the standard contractual clauses can be obtained by writing to the Operator. Data is not sold. Apart from the recipients listed in this section, the Operator shares data only with Lokavi Home partners and only the data of those persons who have consented to the transfer of data to partners (section 5a), within the scope of that consent: first name, e-mail address and – if provided – phone number. Data may be disclosed to authorised authorities if required by law.

5. Who sees data in the home

The home administrator and persons with administrator rights see all data of their home. The coordinator sees tasks, the schedule, registers and reports. A worker sees their own tasks, registers, chat and whatever relates to their work. A household member sees meals, items, shopping, “right now” requests and chat. Data of one home is not visible to other homes.

5a. Marketing and consents

Marketing consents are voluntary, independent of one another and are not a condition for creating an account or using the App. The Operator asks for separate consent for each of the following purposes and contact channels.

Profiling. If you consent to offer matching, the Operator selects offers for your home based on: the number of household members, the presence and age range of children, pets, the size of the home and the use of App features. Health data, workers' data, photos, chat and daily plans are not used for profiling. Profiling serves solely to select offers and does not produce legal effects concerning you.

For the purpose of offer matching, the Operator is the controller of the listed characteristics of the home on the basis of the home administrator's consent; in all other respects, the Operator processes the data entered by the home about its members and workers on behalf of the home administrator.

5b. Shopping agent and AI models (including list reading and store selection)

The shopping agent, reading a shopping list from a photo or dictation and store selection for shopping list items are optional features based on artificial intelligence (AI) models; their responses may contain errors. The agent runs on the Operator's servers. The controller of the data processed in these features is the Operator.

What goes to the AI model. Items of shopping lists and orders (names, quantities, notes, amount limits), answers of the home's users to the agent's questions, the home address (if the administrator has entered it – to choose delivery and check its cost), screenshots of shops taken during shopping (which may show, among other things, the delivery address, the recipient's first and last name and order history), and, for list reading, a photo of the note or the dictated text. Speech recognition is performed by the phone's system or the browser (e.g. Apple, Google) on their own terms; the App receives only the text. When searching for and comparing offers, the agent provides the SerpApi offer search engine with the name of the product searched for and the home's city.

Purpose. Carrying out the order: selecting products, comparing offers, placing the order, converting a photo or text into list items, indicating the store in which the agent is to look for an item. The Operator does not use this data for marketing, profiling or training models. Shopping lists may indirectly reveal health information (e.g. medicines); the Operator does not draw any such conclusions from them.

Model provider. With billing from the balance or subscription (“our tokens”) and always for list reading and store selection, the App uses Anthropic PBC (USA) models on the Operator's account – Anthropic processes the data as a processor on behalf of the Operator. With the home's own API key, the agent uses the home's account with the provider chosen by the administrator from among those made available by the Operator: Anthropic PBC, OpenAI or xAI (all in the USA) – the data goes to the provider on the terms of the agreement the home has concluded with that provider. Store selection does not use the home's key (see below).

Store selection. In a home in which the shopping agent is enabled and the home administrator has given the permission described at the end of this section, after an item is added to the shopping list the App determines in which of the home's stores the agent is to look for it. It first checks earlier store selections (store corrections and purchases) saved for the home's owners and shared across their homes – without an AI model. Where there is no such selection, the AI model receives the item's name and quantity (as entered on the list), the names of the home's stores and the home's shopping preference; the model returns the store and the item's category. Store selection always uses an Anthropic PBC (USA) model on the Operator's account – Anthropic processes the data as a processor on behalf of the Operator – also in a home that has provided its own API key for the agent, including where that home's agent uses OpenAI or xAI; the home's key is not used for this, and item names are not sent to the provider chosen by the home. With the item we save the selected store, marked as indicated by an AI model, and separately – the model, store, category, confidence, time and cost of each model response (without the item name); item names are not written to logs. A store chosen manually or resulting from a product link always takes precedence.

Shop passwords and the API key. The login and password for the shop account and the own API key for the model provider are encrypted on the administrator's phone with their agent's key; the database contains only the ciphertext (for the API key, also the provider name and the last 4 characters). They are decrypted only on the agent server, automatically and for the duration of the agent's work; during that time the Operator technically has access to them. Passwords and the key are not passed to the AI model (the API key goes only to its provider as login credentials), and are not stored in logs, results, notifications, e-mails or screenshots.

Retention. Agent screenshots – 30 days; the list photo and dictated text – are not stored or logged after reading; orders and run results – for as long as the home exists.

Permission in the App. Before first use, the home administrator confirms in the App that they have read these rules and allows data to be passed to the model provider (we record the version of the text, the person and the time). The basis for processing is the contract (section 3), not consent. Permission can be withdrawn at any time by writing to the Operator – the agent, list reading and store selection by an AI model then stop working. Disabling the agent in the App (Agent tab) stops the agent from accepting new orders.

5c. Agent balance and payments

Balance and history. Each home has a payer – one of the home owners with an account (Terms of Service, section 6 point 3). The Operator maintains the payer's agent balance, shared by the homes for which they pay, and the transaction history (top-ups, charges for AI usage with the name of the home, the model and the number of tokens, starter gift, adjustments, refunds). The payer sees the balance and the history of charges in all homes for which they pay. Other owners and coordinators of the home see the charges of their home, and the balance amount – only when the balance relates to a single home. After a change of payer, the previous payer keeps the history of charges from the period in which they paid; they see the charges of a home to which they no longer have access as “another home”, without a description. The balance of a home to which an owner other than the payer made payments remains a separate balance of that home and is visible to all owners of the home. The legal basis is performance of the contract (Article 6(1)(b) GDPR). The record of the granted gift contains the identifier of the home owner's account – so that the gift is granted only once per account.

Payments. Top-ups and orders of the AI subscription take place on the Stripe payment page, only in the browser version of the App. We accept payments from consumers with a billing address in Poland or in another European Union country and from businesses with a Polish NIP and a billing address in Poland: the Operator checks the country of the billing address and the type of tax number, and a payment with a billing address outside the European Union or with a tax number other than a Polish NIP is automatically refunded in full. For a payment from a consumer from another European Union country, the Operator additionally records the billing address country, the amount, the date and the Stripe payment identifier (section 5h). Stripe Payments Europe, Limited (Ireland) processes payer data (including first and last name or company name, e-mail address, card or BLIK details, NIP – if the payer provides it) in order to carry out the payment and – as a separate controller – for its own purposes described in Stripe's privacy policy (e.g. fraud prevention, legal obligations). The Operator receives a payment confirmation from Stripe (identifier, amount, currency, status) and has access in the Stripe dashboard to the payer data needed for an invoice and a refund; it does not receive full card data.

Balance e-mails. Home owners with an e-mail address receive transactional e-mails about the agent balance (welcome, low balance, insufficient funds, change to billing rules), sent by Resend Inc. from agent@send.lokavi.pl. These are not marketing e-mails and do not require marketing consent. After sending, the e-mail address is removed from the sending queue; a record remains that an e-mail of a given type was sent to the home (so as not to send it again).

AI subscription. For the subscription, the Operator processes the Stripe customer and subscription identifier, plan, status, billing periods, subscription payments and invoices, and usage within the limit – for the performance of the contract (Article 6(1)(b) GDPR) and tax obligations (Article 6(1)(c) GDPR).

Statements before payment. Before each payment, the home owner ticks acceptance of the Terms of Service and the request to commence performance before the withdrawal period expires. We record their wording (version), the version of the Terms of Service, the person, the time and the payment identifier – in order to demonstrate conclusion of the contract and settlements (Article 6(1)(b), (c) and (f) GDPR) – and send them in the payment confirmation e-mail.

Withdrawal from the contract. A statement submitted using the “Withdraw from the contract” button contains the first and last name and e-mail address provided in the window, the contract and the time of submission. We send a confirmation to that address, and the Operator receives a notification so that it can make the refund in the Stripe dashboard.

5d. Content reports and appeals

We accept reports of content considered illegal and appeals against the Operator's decisions (section 4a of the Terms of Service) by e-mail. We process the reporter's data (first and last name or company name, e-mail address – unless the report concerns offences against sexual freedom and decency involving minors), the content of the report, the indicated content, the decision and its statement of reasons – in order to handle the report or appeal and fulfil the obligations under the Digital Services Act (Article 6(1)(c) GDPR). The Operator notifies law enforcement authorities of information indicating an offence threatening the life or safety of persons.

Reports of AI content in the App. You can report content generated by AI features (the shopping agent, the virtual AI manager, store selection, the home scan, offers) with the “Report” button, stating the reason and a short description (up to 500 characters – without data of other people). We record the home, the account and the reporting person, the type and identifier of the content (without a copy of it), the reason, the description, the time and the status of the report. Reports are used to check AI content, improve the AI features and comply with the rules of app stores (Apple, Google) – the Operator's legitimate interest (Article 6(1)(f) GDPR). Such a report does not replace the report of illegal content described above. Reports are visible only to the Operator; the number of reports from one account is limited per day.

5e. AI translation

App texts. App labels, system messages and documents in languages other than Polish are translated in advance using an AI model from Anthropic PBC. No user data goes into this translation.

Content entered by users. When the Operator makes available translation of content entered in the home (e.g. chat messages, descriptions of tasks and faults, meals, instructions; excluding the shopping list), the text and the target language will be passed to the AI model of Anthropic PBC (USA, standard contractual clauses) solely for the purpose of showing the translation to people in the home who use the App in another language. The translation is stored alongside the original, marked as translated by AI, with the option of displaying the original, and is deleted together with the original. Anthropic acts as a processor on behalf of the Operator, and with respect to the data of workers and other persons for whom the home administrator is the controller (section 1) – as a further processor; the Operator notifies home administrators by e-mail at least 14 days before this feature is enabled (Annex 2 to the Terms of Service). The legal bases are given in section 3. The home administrator may disable content translation for the entire home. Any person may object to the translation of their content – to the home administrator or to the Operator (section 7). The provider does not use this data to train models, and the Operator does not use the translated content for other purposes; in particular, it does not draw conclusions about health from it.

5f. Shopping agent in other countries

In countries where shops require a connection from an address in that country, the shopping agent may connect to shops through an intermediary service provider (a proxy server in the shop's country). This provider forwards the agent browser's traffic to the shop, including data visible on the shop's pages (e.g. delivery address, cart contents), and acts as a processor on behalf of the Operator. The Operator will state the provider's name in this policy before launching the agent in such a country.

5g. Transfers of data outside the European Economic Area

App data is stored in the European Union (Ireland), including for users outside the Union. Outside the European Economic Area (EEA), data goes only to the recipients indicated in section 4, on the bases stated there: decisions of the European Commission finding an adequate level of protection (including the EU–US Data Privacy Framework where the recipient is certified under it) or standard contractual clauses approved by the European Commission. A user outside the EEA uses the App on the same terms – their data is processed in the European Union.

5h. Taxes on payments

The Operator settles payments from consumers from other European Union countries with Polish VAT as long as the total value of such sales does not exceed the threshold set by VAT law (EUR 10,000 per year). For this purpose it keeps a record of these payments (billing address country, amount, date, Stripe payment identifier) – on the basis of a legal obligation (Article 6(1)(c) GDPR) – and stores it in the same way as other payment data (section 6). When the threshold is exceeded or payments become available outside the European Union, the Operator may use the Stripe Tax service to calculate tax on payments (e.g. VAT according to the payer's country): Stripe receives the payer's country and billing address and – if provided – the NIP or VAT number, in order to determine the applicable rate and for tax documentation.

5i. Home scan and the item register

The home scan is an optional function of the “Items” module and is switched off by default. The home administrator switches it on by their own action and consents to the transfer of images of interiors to an AI model (we record the version of the consent, the person and the date); without this consent, scanning does not work. Scanning also requires the consent to use the AI model described in section 5b.

Who scans. Administrators and household members can scan. Household staff (workers, coordinators, cooks) scan only if the administrator allows it or assigns them a scan of a specific place. Before the first scan, the App asks that no people or open documents be in the frame.

What goes to the AI model. During a scan the phone picks sharp, distinct frames from the camera image (or photos taken by the user) and passes them to the Anthropic PBC model (USA) together with the names of places and items already entered in the scanned place. With dictation, the model receives the text dictated or typed on the place's card. The model returns a list of recognised items and furniture. A schematic room model is also created from the scan frames: the outline of the walls, doors, windows and the position of furniture. An uploaded home plan goes to Anthropic's model for recognition, to read the rooms from it. The data is used solely to recognise items and places in the home; the model provider processes it as the Operator's processor and does not use it to train models. A scan always uses the Operator's account with the provider, including in homes that have entered their own API key for the shopping agent.

What we store. Recognised items go to the “To review” list and become part of the register only after approval by the administrator or by the person who scanned. We store: the names of items, the place, quantity, category, a small crop of the image showing the item, who scanned and when, and the cost of the scan. We store scan frames only if the model did not recognise a person or a document containing data in them; frames with people or documents are not stored at all (they are processed only for the duration of recognition). We do not create crops that show a person or a document. We keep the plan without a time limit until you delete it (“Delete plan”).

Who sees it. Scan frames are visible to home administrators and to the person who scanned. Items and their crops are visible to the people who can see the place where they are kept; items marked as valuable and places marked as private are not visible to household staff.

Billing. A scan is billed like the agent's work (section 5c): from the agent balance or from the home's subscription limit; in a home that has provided its own API key for the agent, the scan is free of charge. Before a scan the App shows a cost estimate, and during it – a counter. Fees for the scan apply from the date version 1.8 of the Terms of Service enters into force (6 December 2026); until that date the scan is free of charge.

Withdrawing consent. Consent can be withdrawn at any time – by switching off the scan in the App (Items → Scan settings) or by e-mail to the Operator; withdrawal does not affect the lawfulness of processing before withdrawal. Approved items remain in the register until the administrator or a household member deletes them.

5j. Virtual AI manager

The virtual AI manager (“Lokavi AI”) is an optional function, switched off by default, based on an artificial intelligence (AI) model. It is switched on by a home administrator with the owner role after reading the information card (we record the version of the card, the person and the time). The manager handles matters from the escalation chain: it reminds of tasks, hands them over to people on shift, reschedules deadlines, closes matters with a reason given by the assignee, writes to workers and passes matters to the administrator; it approves purchase requests only according to the administrator's rules. It does not evaluate workers and does not make decisions on the terms of their work. Its messages and actions may contain errors.

What goes to the AI model. Only the data of one home needed for current matters: the titles, types and deadlines of open reports, the first names of assignees, their languages and reactions in the matter from the last 7 days, reasons for skipping tasks, information on whether there is a photo (without the photo itself), today's schedule (who is on shift, in which position and during which hours), up to 10 most recent messages from workers' threads with the AI manager from the last 48 hours, purchase requests awaiting approval together with the purchase rules, the administrator's instructions for the manager, the time zone and language of the administrator. The following do not go to the model: the home's address, telephone numbers, e-mail addresses, the balance, photos, statements, other chat conversations or data of other homes.

Model provider. Anthropic PBC (USA) on the Operator's account – also in a home with its own API key. With respect to the data of workers and other persons for whom the home administrator is the controller, Anthropic acts as a further processor, and the Operator – as a processor under Annex 2 to the Terms of Service; the transfer to the USA takes place on the basis of standard contractual clauses (section 5g). The Operator does not use this data for marketing, profiling or training models.

Workers. In its first message to a given person, the AI manager introduces itself as artificial intelligence and informs them that the home owner sees the conversation; its messages are marked “Lokavi AI”. Before the manager is switched on, the home administrator informs the workers about this function – the App provides ready-made information, which the workers confirm. A worker may write directly to the home administrator about any matter, and submits an objection to the handling of their matters by the AI manager to the home administrator or to the Operator (section 7).

Log. Each action of the AI manager (type of action, matter, result, a short explanation for the administrator) and each of its runs (time, model, number of tokens, cost) is recorded and visible to the home administrator in the App and in the weekly report. Technical logs do not contain the content of messages or task titles.

Switching off. The home administrator switches off the AI manager at any time with a single button; from that moment the manager does not perform any actions, and the home's data no longer goes to the model.

6. How long data is stored

7. User rights

Everyone has the right of access to their data, to rectification, erasure, restriction of processing and portability of the data, the right to object to processing based on legitimate interest, and the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warszawa). For matters concerning data entered in a specific home, the administrator of that home will be able to help most quickly; you can also write to the Operator.

Consent can be withdrawn at any time, as easily as it was given: More → Marketing consents, the account page or an e-mail to the Operator; withdrawal does not affect the lawfulness of processing carried out before it. Everyone has the right to object to profiling.

Account deletion: on the sign-in page (start), after signing in – “Delete account” (from the App: More → My account → “Account (Apple / Google / email): consents and account deletion”), or by e-mail to the Operator. The home administrator can deactivate a person in Settings → People and delete the entire home in Settings → Home.

8. Children

Only adults may create e-mail/Apple/Google accounts. A child's (household member's) profile is created by a parent or guardian who is the home administrator; such a profile does not require an account or an e-mail address, and the profile is fully controlled by the parent. Children sign in with a PIN or a one-time QR code that the administrator or coordinator displays on their own device. Linking a profile with an Apple or Google account is intended for adults (Apple and Google do not offer this sign-in to persons below the age required by the providers), so the administrator should not enter a child's e-mail address.

9. Security

Connections are encrypted (HTTPS). Passwords and PINs are stored only as cryptographic hashes. Access to data in the database is restricted by isolation between homes at the database level. After 5 incorrect PIN attempts, the account is temporarily locked. The shopping agent and list reading are marked in the App as artificial intelligence (AI) systems: the agent's messages, questions and notifications are labelled “AI agent”.

10. Changes

The Operator will announce material changes to this policy in the App. The current version is always available at the address of this page. The rules for the agent balance, subscription and payments are set out in the Terms of Service.

11. Language versions

This policy is available in several languages. The original text is the Polish version; versions in other languages are translations prepared using an AI tool. If the versions differ, the Operator applies the one that is more favourable to the data subject. Rights under the GDPR apply to the same extent regardless of the language version.