Privacy Policy – LexCH
Last updated: August 2026
1. Data Controller
The data controller is:
Aaron Boccadamo
Danijel Balcakovic
Via Carona 38
6900 Paradiso, Ticino – Switzerland
Email: info@lexlegal.ch
LexCH is not currently registered in the Swiss Commercial Register.
For any questions regarding data protection or to exercise your rights, please contact us at the address above.
2. Scope of Application
This policy applies to the processing of personal data carried out through:
- the LexCH app
- any web pages connected to the service
- registration, login, AI chat, document archive, legal cases, notifications and user preferences features
- communications between the user and LexCH
3. Personal Data Processed
We process data provided directly by the user, data generated during use of the service, and technical data collected automatically.
3.1 Account Data
- email address
- name
- password (hashed, never in plain text)
- profile picture
- login method (email/password, Google, Apple)
- subscribed plan, billing period, activation and expiry date
- preferred language
- email verification status and date
- date of acceptance of terms and newsletter consent
3.2 Access and Technical Data
- IP address
- user-agent (the identifier of the program you connect with: app or browser)
- device name, used to deliver push notifications
- date and time of access
These data serve account security, notification delivery and abuse prevention.
What we do not collect. We do not collect screen resolution, time zone, geographic location, or the country or city you connect from. An earlier version of this policy mentioned these data: the feature that was meant to collect them was never activated and has been removed from the service.
3.3 AI Chat Data
- messages submitted
- AI responses
- conversation title
- technical data (date, time, IP, conversation ID)
3.4 Uploaded Documents
- uploaded files
- file name, type, size
- extracted content and text
- metadata and AI information (deadlines, categories, classifications)
3.5 Personal Document Archive
- uploaded documents
- title, description, category, notes
- extracted text
- linked AI information
3.6 Settings, Preferences and Consents
- language and theme
- preferred canton and municipality
- notification preferences
- AI preferences (tone, style, level of detail)
- cookie or equivalent technology consents
3.7 Push Notifications
- device token
- device name
- platform
3.8 AI Usage Data
- tokens consumed
- date and time of each request
3.9 Temporary Verification and Security Data
- verification or reset codes/tokens
- validity periods and expiry
3.10 Device Permissions
LexCH requests the following device permissions, only if the user explicitly grants them and only when the related feature is first used:
- Camera (
CAMERA): used exclusively for (a) taking a profile photo, (b) scanning paper documents for AI analysis, (c) capturing images to attach to a conversation. Images remain on the device and are uploaded to our servers only if the user confirms sending. No background access and no video recording. - Gallery / Storage (
READ_MEDIA_IMAGES/READ_EXTERNAL_STORAGE): to allow the user to select existing images or documents for analysis or attachment. - Notifications (
POST_NOTIFICATIONS): to receive push notifications (e.g. AI response completed, legal updates, deadlines). Can be disabled at any time from the operating system or app settings. - Internet (
INTERNET): required to communicate with LexCH servers (legal APIs, authentication, AI).
The user may revoke permissions at any time from the operating system settings. Revocation does not result in data loss but may limit certain features.
3.11 Assistant Memory
The assistant can remember what you tell it. The feature is found under Settings → AI Memory and is switched off by default: until you turn it on yourself, nothing you write is extracted or retained for this purpose, and every conversation starts from scratch.
How it works. When memory is on, after each answer an artificial intelligence model re-reads the question/answer pair and extracts the information concerning you. At most 60 items are retained: once the limit is reached, the oldest are replaced by the newest. The categories of information extracted are:
- personal and family data
- canton and municipality
- occupation and employer
- legal problems and ongoing matters
- type of residence permit and AHV/AVS situation
- financial situation
- preferences
The information retained is brought together into a single summary text, which is inserted into subsequent conversations so that the assistant can take it into account without your having to repeat yourself.
The extraction goes through Google. The analysis that produces this information is performed by the AI provider indicated in § 5: for every answer, your question and the assistant's answer are therefore transmitted to Google for this operation as well. The memory summary is then transmitted to Google again in each subsequent conversation in which the assistant is to take it into account.
This is profiling, and we declare it as such. Building and updating a picture of your family, professional, financial and legal situation on the basis of your conversations constitutes profiling within the meaning of the Federal Act on Data Protection. Turning the feature on constitutes your consent to this processing. Further information in § 15.2.
You remain in control. At any time, from Settings → AI Memory, you can:
- read the full list of what the assistant has memorised about you
- delete a single item of information
- delete the entire memory
- switch memory off: from that moment the information retained immediately stops being used and no new information is extracted. Switching off does not delete: if you also want to remove what has already been memorised, use deletion.
4. Purposes of Processing
Personal data is processed to:
- create and manage the account
- provide secure access to the app
- deliver service features, including AI features
- analyse content submitted by the user
- generate responses, summaries, classifications, estimates and suggestions via AI
- store and organise documents in the personal archive
- manage the subscribed plan
- send service communications and verifications
- send newsletters (with consent only)
- improve performance, security and stability
- prevent abuse, fraud and unauthorised access
- fulfil legal obligations or defend rights
- transmit to the AI provider the questions, the conversation context and the documents needed to generate the answers
- ground certain answers in up-to-date sources through Google Search (grounding)
- extract, retain and reuse information concerning you in order to personalise the answers, if you have turned on the assistant memory (profiling)
- send reminders about the expiry dates of the documents you keep in the archive
- recognise the devices you have chosen to have remembered for two-factor authentication
- record the date of acceptance of the Terms of Service and of this policy
5. Use of Artificial Intelligence
LexCH uses artificial intelligence systems to process user-submitted content and provide:
- analysis
- summaries
- classifications
- suggestions
- drafts
- estimates
- identification of relevant elements
AI outputs serve an informational and support purpose and do not constitute legally binding decisions or professional legal advice.
5.1 Who processes your requests
The provider of the artificial intelligence models is Google (Gemini models). LexCH uses a paid plan of Google's programming interface: the conditions described in § 5.3 apply by virtue of that plan.
5.2 What is transmitted to Google
To generate an answer, we transmit to Google, over an encrypted connection (HTTPS with TLS 1.2 or higher):
- the text of your question and the context of the ongoing conversation
- the summary of the assistant memory, if you have turned it on (see § 3.11)
- the complete file, when you ask us something about a document or when you fill in a form: no extract or summary is sent, but the entire document
It follows that everything the document contains is transmitted to Google together with the document, including personal data — yours or third parties' — that is not needed for the question you are asking. For this reason we invite you to upload only the documents genuinely necessary for your request.
The same applies to the assistant memory: if it is on, the picture of your personal situation gathered in earlier conversations is transmitted to Google together with the new question.
5.3 What Google does with these data
- Under the paid plan, Google does not use the content we transmit to it to train its models.
- Google records questions and answers for a limited period, for the sole purpose of detecting abuse and complying with legal obligations.
- Certain answers are grounded in up-to-date sources retrieved through Google Search (grounding), so as to be anchored in the law and the information currently in force. For these requests Google retains the question, the context transmitted and the answer for 30 days. This retention is a condition of the search service: it cannot be switched off, neither by you nor by us.
Data transmitted to Google remain subject to Google's retention periods even after you have deleted them from LexCH or deleted your account (see § 10).
Users are advised to avoid entering unnecessary personal data of third parties.
6. Source of Data
Data is collected:
- directly from the user
- automatically from the device or browser
- from internal technical systems for security and service management
If the user enters third-party data, they are responsible for complying with applicable law.
7. Legal Basis for Processing
We process personal data:
- to provide the requested service
- to manage the relationship with the user
- for legitimate interests (security, stability, abuse prevention, service improvement, legal defence)
- on the basis of consent, where required
- to fulfil legal obligations
8. Disclosure to Third Parties
We may disclose personal data to providers who process data on our behalf, including in particular:
- hosting and cloud infrastructure providers
- AI service providers (e.g. Google Gemini)
- email service providers (SMTP)
- push notification and authentication providers (Firebase – Google LLC; used for push notifications and social authentication via Google Sign-In and Apple Sign-In)
- subscription and payment management providers (RevenueCat Inc.; payment processing is carried out via Google Play Store or Apple App Store – LexCH does not receive or store payment card data)
- analytics or crash reporting service providers
- technical support, maintenance and security providers
Such providers are selected and contractually bound to ensure processing in compliance with applicable law.
Data may also be disclosed to authorities or advisors when required by law or necessary to protect legal rights or interests.
We do not sell personal data.
9. International Data Transfers
To deliver the service we rely on providers that also process data outside Switzerland. They are:
- Google — Gemini models for the artificial intelligence features, and Firebase for Google and Apple sign-in and for push notifications
- RevenueCat — subscription management
- the email service provider, for service communications and the newsletter
- the hosting provider on which the service runs
These providers process data in the United States and in the European Union.
If the destination country does not provide an adequate level of protection, we put in place appropriate safeguards (in particular standard contractual clauses), subject to exceptions provided by law.
Reference: Federal Data Protection and Information Commissioner (FDPIC) – Transfer of personal data abroad.
10. Retention Period
We retain data for as long as necessary for the purposes stated and, thereafter, for legal obligations or defence of rights.
In particular:
- temporary conversations without an account: 2 hours, then deleted automatically
- accounts registered but never verified: deleted after 30 minutes
- log of AI feature usage: 12 months
- email verification and password reset tokens: 7 days, or until they expire if earlier
- sessions (access renewal tokens): 7 days
- devices remembered for two-factor authentication: 30 days
- account data and preferences: for the duration of the account
- conversations: until you delete them or delete your account
- documents in the archive: they remain until you delete them. If you set an expiry date for a document, you receive a reminder 7 days and 3 days beforehand
- assistant memory: until you delete it or delete your account (see § 3.11)
10.1 Account deletion
When you delete your account, your data are deleted immediately, including the files kept in the archive. We do not retain a copy in case you change your mind: deletion is final.
An exception applies to what has already been transmitted to Google to generate the answers: those data remain with Google for the periods indicated in § 5.3 and we cannot have them deleted earlier.
11. Data Security
The protection of our users' data is an absolute priority for LexCH. We apply the highest industry security standards to ensure that your personal information, your AI assistant conversations, and your documents remain private, confidential, and accessible to you alone.
Our technical and organisational measures protect personal data from:
- unauthorised access
- loss
- misuse
- alteration
- unlawful disclosure
Measures include access controls, credential protection, strict internal access restrictions, security event logging, continuous monitoring, and further measures proportionate to the risk.
11.1 Encryption of data at rest
Your personal data and the content you generate are encrypted with AES-256-GCM — the same standard used by banks and public administrations — before being saved to the database. The key is not in the database: it is held on the application server, separate from the data it protects.
In practice: anyone obtaining a copy of the database — a hosting provider, a system administrator, an attacker — would find only encrypted text, unusable without the key.
What this does not mean. This is not zero-knowledge encryption: the server holds the key and therefore has the technical ability to decrypt your content. It does so when this is needed to answer you — to send your question to the AI assistant, to read a document you ask us about, to extract its text, or to fill in a form. Outside these operations, and subject to legal obligations, nobody reads your content and it is not used to train artificial intelligence models.
We say this plainly because a service that processes your documents with artificial intelligence cannot, by its very design, be zero-knowledge: in order to process them, it must be able to read them.
Data protected by AES-256-GCM:
User profile
- email address
- name
- preferred canton and commune
AI conversations
- conversation titles
- full content of every message (user questions and AI answers)
Personal document archive
- title, description, notes
- original file name
- extracted text and document content
- the binary file itself, encrypted directly on disk
Notifications and devices
- device token (FCM)
- device name
Security logs
- IP address, user-agent, screen resolution, timezone, country, city, device name (used exclusively for account security and also encrypted)
Credential protection:
- Passwords are never stored: transformed with Argon2id (algorithm recommended by OWASP 2024), they cannot be reconstructed — not even by us.
- Session, email verification and password reset tokens are protected with cryptographic hashing.
- Email lookup at login uses HMAC-SHA256 blind-index, without exposing the address in plaintext.
11.2 Secure transmission
All communications between the app, the website and our servers take place exclusively over HTTPS with TLS 1.2 or higher, with a valid certificate issued by a recognised certification authority. The same applies to the data we transmit to the providers indicated in § 5 and § 8. Your data are therefore protected both in transit and at rest.
This is not end-to-end encryption. Encryption in transit protects the path between your device and our servers: it prevents anyone from intercepting the data while they travel, but on arrival the server decrypts the content, because in order to answer you it must be able to read it. It is the same reason explained in § 11.1.
With end-to-end encryption, not even the service provider can read the content. An assistant that analyses your questions and your documents cannot work that way, and we prefer to say so plainly rather than use a word that sounds better than what we actually do.
11.3 Our commitment
We consider the privacy of our users a core value. LexCH has been built so that your legal data, your AI questions and your documents remain exclusively yours.
12. Newsletter and Communications
If you have given your consent, we may use your contact details to send:
- newsletters
- updates
- informational or promotional communications relating to LexCH
You may withdraw your consent at any time via:
- the unsubscribe link
- the app settings
- email to info@lexlegal.ch
13. Push Notifications
If you enable push notifications, we may send you operational, informational or service-related communications to your device.
You may disable them at any time from the app or device settings, using the available options.
14. User Rights
To the extent permitted by applicable law, you have the right to:
- know whether we process personal data relating to you
- obtain information about the data processed
- request correction of inaccurate data
- request deletion of data, where permitted
- object to certain processing
- withdraw consents given, with effect for the future
- request information about the existence of automated individual decisions
14.1 What you can already do yourself, right away, in the app
- view and delete the assistant memory — Settings → AI Memory: read the full list of the information memorised, delete a single item, delete all of it, switch the feature off
- delete a conversation — from the list of conversations
- delete a document — from the document archive
- delete your account — Settings → Privacy & Security: deletion is immediate and includes the files (see § 10.1)
- withdraw your newsletter consent — see § 12
- disable push notifications — see § 13
14.2 What you have to ask us for in writing
The app does not yet have a feature that exports your data into a file. If you want a copy of the data concerning you, or the correction of data you cannot amend yourself, or to object to a particular processing operation, write to us at info@lexlegal.ch and we will take care of it.
Swiss law (FADP) provides:
- right of access with a response, as a rule, within 30 days
- duty to inform in the event of automated individual decisions, in the cases provided by law
14.3 Complaint to the supervisory authority
If you consider that the processing of your data does not comply with the law, you may contact the Federal Data Protection and Information Commissioner (FDPIC), the competent supervisory authority in Switzerland. Recourse to the courts remains available.
15. Automated Decisions and Profiling
15.1 Automated decisions
LexCH uses automated tools and AI systems to provide support to the user.
The service does not take automated individual decisions producing legal effects concerning you or similarly significantly affecting you: what the assistant produces is information, analysis and proposals, which remain subject to your assessment and your decision. Automated checks necessary for the operation and security of the service are excluded from this, such as the management of the limits of the plan subscribed to and measures against abuse.
Should a specific feature involve an automated individual decision within the meaning of applicable law, you will be informed as required by law.
15.2 Profiling
The assistant memory described in § 3.11, when you have turned it on, constitutes profiling: automated processing which, on the basis of your conversations, builds and updates a picture of you — family situation, canton and municipality, occupation and employer, ongoing legal matters, residence permit and AHV/AVS situation, financial situation, preferences.
Regarding this profiling, we wish to make the following clear:
- it serves solely to personalise the assistant's answers
- it is not used to take decisions about you, to assess your trustworthiness or to determine which features or prices are offered to you
- it does not feed advertising and is not disclosed to third parties beyond what is indicated in § 5 (the extraction and the use of the summary go through the AI provider)
- it is switched off by default: it is activated only by your choice, and that activation constitutes your consent
- you can switch it off, consult it and delete its content at any time, from Settings → AI Memory
Outside this feature, LexCH does not carry out profiling of users.
16. Minors
LexCH is intended for individuals capable of using the service independently and responsibly.
Those using the app represent that they have the capacity required to do so under applicable law.
If we become aware that personal data has been processed in a manner inconsistent with applicable age or consent rules, we will take reasonable measures to limit or discontinue such processing.
17. Changes to this Policy
We may update this privacy policy at any time, in particular in the event of:
- changes to the service
- changes to AI features
- changes in the providers used
- new applicable legal obligations
The updated version will be published in the app and/or on relevant channels, with an indication of the last update date.
18. Contact
For questions about this policy or to exercise your rights, contact us at:
Aaron Boccadamo
Danijel Balcakovic
Via Carona 38
6900 Paradiso, Ticino – Switzerland
Email: info@lexlegal.ch