Privacy Policy

Last updated May 5, 2026

This privacy notice for Napkin GmbH ("we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you use our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use — including the content of the Ideas (notes) you create.

Do we process any sensitive personal information? No. We ask that you do not include sensitive personal information (such as health, financial account numbers, or government IDs) in your Ideas. If you choose to do so, that content is processed under the same technical and organizational measures as all other content but is not specially categorized.

Do we collect any information from third parties? No. We do not purchase or receive personal information about you from data brokers or other third parties.

Do we share your information with third-party service providers? Yes — we use a small number of carefully selected service providers to operate the Services (cloud infrastructure, AI processing, customer support, payment processing via the Apple App Store, and email/marketing). The full list, with purpose and region, is in Section 4 below. We do not sell your personal information and we do not share it for advertising.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which parties do we share personal information? We share information with named service providers (Section 4) and may share in connection with corporate transactions or legal obligations. The full list and the legal basis for any international transfers are described in Sections 4 and 4a.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100 % secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may give you certain rights regarding your personal information.

How do you exercise your rights? The easiest way is by visiting https://napkin.one/r/support, or by contacting us at [email protected].

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Idea content. Napkin is a note-taking app organized around digital notecards called "Ideas". The text and links you save into your Ideas are personal information for the purposes of this notice. We treat Idea content as private by default — only you can view it through your authenticated account, except where you explicitly share it. Idea content is processed by certain of our service providers (see Section 4) and, in limited cases, by AI providers (see Section 4b).

Sensitive information. We do not actively process sensitive personal information (such as health data, financial account numbers, government IDs, or biometric identifiers). We ask that you do not include this kind of information in your Ideas. If you do, we cannot identify it as sensitive and therefore cannot apply special-category protections to it.

Payment data. We do not collect or store payment card data ourselves. All paid subscriptions are processed by Apple via the App Store and StoreKit. We receive only the transaction receipt, subscription status, and Apple's anonymized transaction identifier from Apple — never the underlying card details. Apple's privacy notice for App Store data is available at https://www.apple.com/legal/privacy/data/en/app-store/.

Application data. If you use our application, we may also collect:

This information is primarily needed to maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you use our Services.

We automatically collect certain information when you use the Services, primarily for security, operation, troubleshooting, and internal analytics:

We do not use third-party analytics SDKs or advertising trackers in the application.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for the following purposes:

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU, EEA, the UK, or Switzerland, this section applies to you.

The General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection (revFADP / revDSG) require us to explain the valid legal bases we rely on in order to process your personal information:

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including for fraud prevention, in business transactions, in connection with employment-related collection, where information is publicly available, or where required by law.

In Short: We share information with a limited number of service providers ("processors") that help us operate the Services. We do not sell your personal information.

We use the following service providers. Each is bound by a data processing agreement that requires them to process your data only on our instructions and to apply appropriate technical and organizational security measures.

In addition, we may share or transfer your information:

We do not sell your personal information, we do not share it for cross-context behavioral advertising, and we do not enable third-party advertising trackers in the Services.

The European Union, United Kingdom, and Switzerland regulate transfers of personal data outside their territories. The primary storage of your account data and Idea content takes place inside the European Union (Supabase, Frankfurt). However, certain service providers listed above process data outside the EU/UK/Switzerland.

For each transfer outside the EU, UK, or Switzerland, we rely on at least one of the following lawful transfer mechanisms:

You can request a copy of the transfer mechanism applicable to a specific provider by contacting [email protected].

We use third-party AI providers (Anthropic and Cohere) to enable two features:

What we want you to understand:

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than twelve (12) months past the termination of your account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process — including encryption in transit (TLS) and at rest, role-based access controls within Napkin GmbH, and contractual security commitments from each of our service providers. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100 % secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (such as the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information.

You can make such a request by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner (FDPIC / EDÖB).

Withdrawing your consent: Where we rely on your consent, you have the right to withdraw it at any time, without affecting the lawfulness of processing before the withdrawal. To do so, contact us using the details below or update your preferences in the application.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing emails at any time by clicking the unsubscribe link in any email we send, or by contacting us. We may still send you service-related messages (e.g. password resets, billing notices) that are necessary for the administration of your account.

Account information. If you would like to review or change information in your account or terminate your account, you can log in to your account settings and update your account, or contact us. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. We may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at [email protected].

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

We have collected the following categories of personal information in the past twelve (12) months:

In addition, we collect the content of the Ideas (notes) you create in the application. Idea content is treated as Identifiers (Category A) only insofar as it is associated with your account; we do not analyze it to derive Category C, G, or K data.

We will use and retain the collected personal information as needed to provide the Services or for:

You. Your device. Apple Inc. (Apple User ID, transaction status). We do not purchase personal information from data brokers.

See Sections 2 and 4 above. We disclose personal information to our service providers under written contracts that limit them to processing on our instructions only.

We have not sold and do not sell personal information. We have not shared personal information for cross-context behavioral advertising and do not do so.

In the preceding twelve (12) months, we have disclosed personal information for business purposes to the service providers listed in Section 4 (Supabase, Apple, Anthropic, Cohere, Intercom, Mailchimp). The categories of personal information disclosed correspond to each provider's processing scope as described in that section.

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Depending upon the state where you live, you may also have:

To exercise these rights, you can contact us by visiting https://napkin.one/r/support, by emailing us at [email protected], or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal. If your appeal is denied, you may submit a complaint to your state attorney general.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We do not disclose personal information to third parties for direct marketing purposes.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

Napkin GmbH Zahnradstrasse 22 8005 Zurich Switzerland

For Swiss data subjects, you may also contact the Federal Data Protection and Information Commissioner (FDPIC / EDÖB) at www.edoeb.admin.ch.

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://napkin.one/r/support.