ETLYON privacy policy
Version 1.0 · 6 October 2026 · English (also in French and German; if the versions differ, the English one prevails)
In short
- Who we are. ETLYON Sàrl, Rue de la Flèche 5, 1207 Genève, Switzerland. Write to contact@etlyon.com about anything in this policy.
- What this covers. Our website etlyon.com and its French version ch.etlyon.com, the ETLYON Academy, and eBot (the app on the web, Mac, Windows, Linux, Android and iPhone, and the AI agents behind it).
- Where your data lives. On our own servers in France, near Geneva, and with Infomaniak in Switzerland. What you write to an AI agent is sent to the AI provider that runs that agent; some of these providers are in the United States (section 5.4).
- What we never do. We do not sell your data, show advertising, track you across websites, or use your conversations to train AI models.
- Your rights. You can ask us what we hold about you, have it corrected or deleted, and complain to the Swiss or your European data protection authority (section 10).
1. Who is responsible
ETLYON Sàrl, Rue de la Flèche 5, 1207 Genève, Switzerland (UID CHE-333.831.765) is responsible for the processing described in this policy. Contact: contact@etlyon.com. We have not appointed a data protection officer; contact@etlyon.com reaches the people who handle data protection at ETLYON.
2. When we decide, and when your organisation decides
eBot is used in three ways. Who is responsible for your data depends on which one applies to you.
- Our own services. For the website, the Academy, support, reports you send us, and the eBot service we run for our own team and for people who use it directly with us, ETLYON decides why and how your data is used (we are the "controller").
- eBot run by ETLYON for your organisation. If your employer or organisation gave you access to eBot, your organisation decides how your data is used, including who in the organisation can read conversations and how long they are kept. ETLYON processes the data on its behalf and only on its instructions (we are its "processor"), under a written agreement with it. Your organisation's own privacy information applies first; please ask your organisation about it. This policy explains what ETLYON does as its processor.
- eBot you install yourself. If you install eBot on your own computer or server, your conversations stay on your installation and go to the AI providers you choose there. ETLYON does not receive them. We only receive what section 5.10 describes.
3. The laws that apply
We apply the Swiss Federal Act on Data Protection (FADP) and, where you are in the European Union or the European Economic Area, the EU General Data Protection Regulation (GDPR). Under Swiss law, processing that respects the principles of the FADP does not need a justification. Where one is needed, or where the GDPR applies, the table in section 4 gives the legal basis for each purpose.
4. What we use, and why
| Purpose | Data | Legal basis under the GDPR |
|---|---|---|
| Answering your enquiries (contact form, e-mail) | Name, e-mail address, organisation, your message, the page you came from | Our legitimate interest in answering you; or steps before a contract |
| Running your Academy account | Name, e-mail address, password, course progress, quiz activity | Contract (providing the course you joined) |
| Providing eBot | Account and sign-in data, conversations, files, voice messages, settings, agent memory, saved logins, connected accounts (section 5) | Contract with you or, when we act for your organisation, its instructions |
| Delivering notifications to your phone | Device registration, notification routing data (section 5.6) | Contract; you can switch notifications off on your device |
| Keeping the service secure and working | Technical logs (section 6) | Our legitimate interest in security and reliability |
| Reviewing reported answers and improving our agents | Reports you send us; for our own eBot service, conversations reviewed to check how agents perform | Our legitimate interest in safe and useful agents |
| Meeting legal obligations | What the law requires, for example invoices | Legal obligation |
We do not take decisions about you based solely on automated processing that have legal effects or similarly significant effects on you. eBot's agents carry out tasks you ask for; they do not decide about you.
eBot is for adults aged 18 and over.
5. eBot in detail
5.1 Your account
Accounts are created by your organisation's administrator (or by us for our own team); there is no public sign-up. We hold your name, your e-mail address, your username, which organisation you belong to, your role, and your sign-in sessions and devices. Sign-in e-mails are sent through Infomaniak.
5.2 Conversations, files and voice
Everything you exchange with an agent is stored on our servers: your messages, the agents' answers, photos, documents and voice messages you send (up to 25 MB per file), reactions, approvals, and your settings (for example how your agents are arranged). Conversations between you and agents are not end-to-end encrypted: our servers need to read them so that the agents can work. They are encrypted while travelling over the internet.
When you dictate, your recording is sent to Mistral AI to turn it into text; we do not keep the recording, only a technical record of who dictated, when, and the size of the recording. When an agent answers aloud, the text is sent to Mistral AI to turn it into speech.
5.3 Who can read your conversations
- You, and the people you add to your own assistant.
- The people responsible for an agent (its "owners") can read the conversations held with that agent.
- In an organisation, the administrator can read people's conversations with their assistant if the organisation has switched this on ("Admin sees"). Your organisation must tell you whether it has. Data stays on the server either way.
- ETLYON staff look at conversations only where needed to provide support, keep the service secure, review a report, meet a legal obligation, or, for our own eBot service, check how agents perform. When we act for your organisation, we do so only on its instructions.
5.4 AI model providers
To answer you, an agent sends your message, the relevant part of the conversation, files you share with it and what it remembers about the task to the AI model that runs it. You can ask us which model an agent uses. Today we use:
- Mistral AI (Paris, France). Mistral runs some agents, our speech features (speech-to-text and text-to-speech), and the summaries and search index of our agents' memory. Mistral processes this on our behalf and stores it in the European Union. It keeps requests for up to 30 days to detect abuse, and does not use them to train its models.
- OpenAI (ChatGPT) and xAI (Grok). Some agents currently run on ETLYON's own ChatGPT and Grok subscriptions. For these subscriptions, OpenAI and xAI apply their own consumer terms and act as independent controllers, not on our behalf. They process the content in the United States. Their terms allow them to use content to improve their models unless this is switched off; we have switched it off for the accounts eBot uses.
- Other providers your organisation or you may add, such as OpenRouter or Ollama Cloud (both in the United States). When a provider is added to an agent, it receives what that agent processes. Where your organisation lets you add your own key, the provider you choose processes your requests under your own agreement with it.
We do not use your conversations to train AI models, and we do not allow the providers that work on our behalf to do so.
5.5 Agents' computers, saved logins and connected apps
- Agents' computers. Each agent has its own computer on our servers, with a web browser it uses for your tasks. The websites it visits see the agent's visit, not your identity, unless your task requires it to sign in. People allowed to use an agent's computer can watch and control it. When you teach an agent by showing it a task, the screen is recorded for that lesson.
- Saved logins. Usernames and passwords you save for an agent are stored encrypted on our servers. Agents never see the passwords: a separate service types them into the website. People allowed to manage an agent's logins can view them.
- Connected apps. When you connect an app (for example Nextcloud, Infomaniak kSuite, Microsoft 365 or your e-mail), the agent receives access to that app with the account you connected, and uses it for your tasks. The access keys are stored on our servers until you disconnect the app. The app's provider processes what the agent does there under your or your organisation's agreement with it.
- Web search. When an agent searches the web, the search words are sent to a web search service.
5.6 Notifications
To show "Your assistant answered or needs you" on your phone, we send a notification through Google Firebase Cloud Messaging (Android and iPhone) and, for iPhone, Apple's Push Notification service. The notification contains this short text and technical identifiers of the conversation and message. It never contains your messages. We keep your device's notification registration until you sign out or switch notifications off, the notification queue for 1 day and delivery records for 7 days.
5.7 On your device
The eBot apps keep your sign-in session, your preferences and unsent drafts on your device. Photos and documents you capture stay on your device until you choose to send them. The Android app does not use Firebase Analytics and excludes its data from device backups. The apps ask for the microphone only when you use voice, for the camera only when you take a photo, and for notifications only if you want them. They do not use your location, read your contacts, show advertising or track you.
5.8 Reporting an answer
If you report an agent's answer, we receive the answer you selected, the agent's name, the time, your name and account, the reason and your comment, by e-mail at contact@etlyon.com. We use reports to review and improve our agents.
5.9 Conversations with people outside your organisation
eBot runs on Matrix, an open messaging standard. Our own Matrix server can exchange messages with the public server matrix.org. This only applies if someone in our own team talks with a person registered there. Organisations we run eBot for do not exchange messages with other servers unless they ask us to enable it.
5.10 If you install eBot yourself
Your installation sends us nothing about your conversations. We receive only:
- your downloads and update checks, which pass through our website (section 6);
- notifications, if you choose to use our notification service (section 5.6);
- anything you send us yourself, such as a report or a message.
6. Website and technical logs
- Contact form. The form asks what brings you here, your name, e-mail address, organisation or professional context, and a short description; you may add your role, the result you are looking for, timing and language. The website and the page you came from are recorded with the enquiry. It is stored in our customer-relationship system and seen by the ETLYON people who handle enquiries.
- Academy. The ETLYON Academy trains people to use ETLYON's technology, such as eBot, and to build things themselves. You can view the public course page and the free preview lesson without an account. To join the full course you create an account with your name, e-mail address and password; we record your enrolment, progress and quiz activity so you can continue the course.
- Cookies. The website uses only the cookies it needs to work: a session cookie (7 days), your language (1 year) and your time zone. Videos and other content from other websites (for example YouTube) are blocked until you accept them in the cookie bar. We do not use analytics or advertising cookies. The eBot apps use only what they need to keep you signed in.
- Logs. When you visit our websites or use eBot, our network entry point records your IP address, the time, the page requested, the result and your browser type. These records are deleted after 14 days. For eBot, the record leaves out search terms and other parameters. Our Matrix server keeps the IP addresses used to sign in for 28 days. Our servers' system logs are limited in size and overwritten automatically, usually within a few weeks.
7. Where your data is, and transfers abroad
- Our own servers, which hold eBot's conversations, files, agents, memory and saved logins, our notification service and the website, are in France, near Geneva.
- Infomaniak Network SA (Geneva) hosts our network entry point, the servers that link agents to connected apps, our file storage (including encrypted backups) and our e-mail, in data centres in Switzerland.
- France and the other EU/EEA countries offer adequate protection under Swiss law.
- Where data goes to the United States (OpenAI, xAI, OpenRouter, Ollama Cloud, Google, Apple), the recipient is either certified under the Swiss-US and EU-US Data Privacy Frameworks (Google) or bound by the European Commission's standard contractual clauses, adapted for Switzerland where needed. You can ask us for a copy of these safeguards.
8. How long we keep data
| Data | How long |
|---|---|
| Enquiries | As long as needed to answer and follow up, then deleted or anonymised, unless an open request, a dispute or a legal duty requires keeping them |
| Academy account and progress | Until you close the account or ask us to delete it |
| eBot conversations, files and agent memory | We do not delete them automatically. They are kept as long as the account or your organisation's service exists. Organisations decide how long their data is kept; when an organisation's contract ends, we return or delete its data as agreed |
| Saved logins, connected apps | Until they are removed or disconnected |
| Notification records | Registration until sign-out; queue 1 day; delivery records 7 days |
| Reports | As long as needed to review the report and improve our agents, at most 2 years |
| Website and network logs | 14 days |
| Sign-in IP addresses | 28 days |
| Encrypted backups | About 5 weeks (7 daily and 4 weekly copies) |
| Invoices and accounting records | 10 years, as Swiss law requires |
9. Security
eBot runs on servers we operate ourselves, each agent in its own separate account. Data travels encrypted over the internet. Saved passwords and backups are stored encrypted. Access to our systems is limited to the people who need it.
10. Your rights
You can ask us:
- whether we process data about you, and for a copy of it;
- to correct inaccurate data;
- to delete data or restrict its use;
- to receive data you gave us in a common electronic format;
- to stop using data on the basis of our legitimate interest (you can object).
Where you gave consent, you can withdraw it at any time.
Write to contact@etlyon.com. Do not send passwords. We may ask you to confirm your identity, and we normally answer within 30 days. If your access to eBot comes from your organisation, we will forward your request to it or help it answer, since it decides about that data.
You can also complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch) or to the data protection authority where you live or work in the EU/EEA.
11. Changes
We update this policy when our practices change and show the date at the top. If a change matters for you, we tell you in the app or by e-mail before it takes effect.
Version history: 1.0, 6 October 2026, first policy covering the website, the Academy and eBot.