Fractal privacy notice

This notice takes effect on 14 November 2026.

This notice is about Fractal, at fractal.echofold.ai: what we keep about you, why, who else handles it, how long we keep it, and your rights. Your Claude or ChatGPT subscription and your GitHub account are between you and Anthropic, OpenAI and GitHub, and their own privacy policies cover them (section 7).

1. Who we are

Echofold Limited ("we" and "us"), a company registered in Ireland, number 786573, at Unit 1, Richview Office Park, Clonskeagh, Dublin 14, D14 W6X6, Ireland, is responsible for the personal data this notice describes (the "controller"). Email support@echofold.ai about anything in it, including your rights in section 11.

2. The short version

Your code stays in your own GitHub repositories and on your own Cloud machine. We don't copy it, or your files, your terminal output, your agents' conversations or your credentials, into Fractal's own storage.
We keep your account, your plan and billing records, how much Fractal AI you've used, and your boards and workflows, which are encrypted.
Frack and Rua's conversations aren't saved anywhere. They're in your browser tab while it's open, and gone when it closes.
Once you're signed in, Fractal has no analytics, advertising or tracking cookies or scripts. Our public pages (the landing page, pricing and the pages about each application) use Google Analytics, and only if you say yes (section 8).
Some other companies help us run Fractal. Section 7 lists them and what each one gets.

3. What we keep, and why

What	What it's for	Legal basis
Your Fractal login: email address, name, password (AWS keeps it only in a form that can't be read back), account ID and authenticator settings. Since 4 November 2026 it's Fractal's own, apart from Echofold's training site.	Signing you in, and keeping your account safe	Our contract with you
Your invitation: a hash of your email address, your code stored only in a form that can't be read back, and what it lets you buy; and your email address in the admin panel's list of invitations	Checking the code is yours, and using it once	Steps you ask for before a contract
A card used in a payment that was charged back through the bank (a chargeback): Stripe's fingerprint of the card (a code Stripe makes from the card number, which can't be turned back into it), when it was disputed, Stripe's ID for the dispute, and whether and when the block was lifted; and, on the billing account of the person who disputed, whose payment it refused, or whose added card we removed, which fingerprint it was. Never the card's number, expiry, brand or name. The fingerprint holds no card details, but it can be linked to a person through Stripe's records of the dispute, and it may belong to someone whose card was misused. While the block lasts, the fingerprint is also on a block list we keep in Stripe, so that Stripe can decline the card before it is charged	Stopping a card that was used to take a payment back from buying Fractal again (section 14)	Our legitimate interest in preventing fraud
A card or other payment method you add later that we removed from your account (section 14), and why, on your billing account until you add a card that is accepted	Telling you and our admins why your card was removed	Our legitimate interest in preventing fraud
That you changed your billing address to one outside where Fractal is sold, and when, so your plan won't renew (section 14), and when you changed it back, on your billing account until you change it back, or, if we set your plan to end, until you renew it or that plan ends. Not the address itself: Stripe keeps that	Telling you and our admins why your plan won't renew	That we sell Fractal only where we account for VAT: Ireland, and the UK once we open there
If you dispute a payment with your bank: evidence for a payment you dispute, which we send to Stripe for your bank: your plan, the dates the payment paid for, which version of our terms you accepted and when (at sign-up and at checkout), when you accepted your invitation, when your Cloud machine was last made ready for you, and when you last signed in. Never anything of your work: no code, files, terminal output, agents' conversations, boards or workflows. We don't keep a copy	Answering the dispute, showing your bank the service you paid for was provided	Our legitimate interest in defending a payment you dispute, and in establishing, exercising or defending legal claims
A payment for a plan we refused and refunded (section 14), and why, on your billing account until a later payment goes through	Telling you and our admins why your plan didn't start	For a blocked card, or a card not issued in the European Economic Area or the UK, our legitimate interest in preventing fraud. For your billing address, that we sell Fractal only where we account for VAT: Ireland, and the UK once we open there
Your plan and billing: your plan, its status and paid-through date, your Stripe customer, subscription and invoice IDs, your checkouts, and your beta place	Giving you what you've paid for, and keeping our accounts	Our contract; the law on keeping financial records
Your Fractal AI use: by day, by month and in total, what it cost, how much text went in and out, how many requests, characters spoken, seconds listened, searches and pages read; and, for each Edit with AI request and each brief Plan's AI reads, its cost, model and time	Your €20 a month and the daily limits, and checking our providers' bills	Our contract; our legitimate interest in checking costs
Your boards and workflows, encrypted: kanban cards (their text, status, labels, links and comments), board settings, workflows, your private strategy board (goals, ideas, decisions, evidence notes, source links and connections), and research collections you choose to save (topic, source details, summaries, notes and connections). Not encrypted: the IDs, times, sizes and versions of each save.	Keeping your work safe off your machine, and showing it to you	Our contract
Your projects: their names and settings, and the GitHub repository each is connected to	Opening the right project	Our contract
Your GitHub connection: GitHub's sign-in tokens for Fractal, your GitHub user ID and username, and the names of your repositories (for 30 days)	Letting Fractal work in the repositories you choose	Our contract
When you last used Fractal, at most once an hour	Showing admins who is active	Our legitimate interest in running Fractal
Your settings: whether the guided tour of Fractal Code opens for you, whether you share your Dreamer's reports with the Fractal team (and whether that was your choice or your group's default), when you set those two, and whether you've answered the dashboard's "What do you want to do?" (not what you chose). A yes to sharing on the sign-up form waits, under a hash of your email address, until you first sign in, for up to 14 days	Remembering your choices wherever you sign in	Our contract with you
Your machine's reports: every 15 minutes it sends its software versions, health, free disk, certificate, whether Claude and Codex are signed in, its scanner results, how many sessions are open, and 14 days of token, message and cost counts; once a day, its installed packages	Looking after your machine, and keeping it secure	Our contract; our legitimate interest in security
Feedback you send: your message, rating and mood, your email address, the page you were on and your browser	Reading it, and answering you	Our legitimate interest in making Fractal better
Your Dreamer's reports (you choose on the sign-up form or in Settings): once a day your Cloud machine sends the Portal a summary of how its agents worked: counts and timings of tool calls, errors and waits, how long tickets waited and how many ran at once, which agents ran and on how many projects and days, and a few examples of what went wrong, each cut down to the programs, flags and known words a command used, with everything else replaced and your project names taken out, plus where in Fractal's code to change it. If you don't share, the Portal drops it without posting or keeping it. If you do, the Portal posts it to our team's Discord channel and keeps nothing; your first post after you turn sharing on covers every day reviewed so far, including days before you did. The post names your machine by its ID, not by your name, but we can match that ID to your account	Seeing how Fractal's agents work in practice and where to improve them	Your consent where you chose to share; for beta testers and the team, sharing is on until you turn it off in Settings
If you join the waitlist on our public pages: your email address, on the Echofold newsletter's list	Sending you your invite code, and Echofold's newsletter	Your consent. Every email has an unsubscribe link, and Echofold's own privacy policy, at echofold.ai/privacy, covers the newsletter
If you say yes to analytics on our public pages: which of those pages you opened and how you came to them, your browser and device, and roughly where you are, worked out from your IP address	Seeing which public pages are read, so we can make them better	Your consent, which you can take back at any time with Cookie settings at the foot of those pages
Emails between you and us	Answering you	Our contract, or our legitimate interest in answering you
A record of every change an admin makes in the admin panel, naming accounts by ID only	Being able to check what any admin did	Our legitimate interest in security and accountability
Server logs	Finding and fixing faults and attacks	Our legitimate interest in security

AWS's hosting also keeps an access log of each request to the Portal: your IP address, your browser and the address you opened. AWS keeps these logs for as long as the Portal is hosted with it, and we read them only to find faults and attacks.

4. What we don't keep

Your code, repositories, files, worktrees, terminal output, agents' conversations and logs, and the credentials you save in Secrets. They stay on your Cloud machine, and your code in GitHub.
What Plan reads from your code. When you start a plan from a project's repository and ask Plan to read it, Fractal's GitHub service reads that repository's file names and dependency files in memory, keeps only a few fixed labels (such as "TypeScript" or "Payments") for your plan, and stores none of it.
Frack and Rua's conversations: what you say or type to them, pictures you show them, recordings of your voice and their replies pass through for each request and aren't saved. Only the counts in section 3 are kept.
The text you send to Edit with AI. It isn't stored or logged.
Documents you attach in Plan. They're read in your browser and never uploaded. If you ask Fractal's AI to fill in your plan from a brief, its text is sent for that one request, and isn't stored or logged. When you hand a plan to Fractal Code, the first 600 characters of your brief go with it, into your project on your machine.
Files you add to a workflow run. They stay in your browser until the run starts, then go straight to your Cloud machine.

Your strategy board is private to your account. Strategy saves the cards and links you enter; it does not import files, fetch source links or send its content to AI providers. Unsaved strategy edits stay in the open tab only.

Research is also private to your account. Before gathering sources or answering questions, it asks you to agree to send your topic, public source excerpts and selected notes to our AI and web providers. Fractal does not store the raw web excerpts. Results stay in the open tab until you press Save encrypted; this saves the topic, source titles and addresses, short summaries, read times, whether an excerpt was shortened, and notes with their topic and source connections. Your questions, generated answers and task progress are not saved. Research collections are removed when you delete your account, along with your other workspace records.

5. How your boards and workflows are protected

They're encrypted on your machine, or in your browser, before they're saved, with a key that belongs to your account.
AWS's key service (KMS) made that key. We keep its private part only in a wrapped (encrypted) form, tied to your account.
Only the Portal's own server can unwrap it, only while you're signed in, and only to work with your boards and workflows for you. The rules on the key refuse everyone else, the people who run Fractal included, and AWS logs every use of the key.
An unwrapped key is never logged, sent anywhere or stored, and a copy of our database on its own opens nothing.

So our server can read the saved copies of your boards and workflows while you're signed in, to show them to you. The boards you're working on are also on your Cloud machine, on its encrypted disk (section 6).

6. Your Cloud machine

It's a virtual server we rent from Contabo, for your account alone. Contabo runs it in one of its data centres in the European Union.
Your projects, settings, worktrees, Secrets, agents' conversations and logs are on an encrypted part of its disk. The key is held in AWS and sent to the machine, encrypted, each time it starts, so a copy of the disk is no use to anyone.
That protects a copy of the disk. It doesn't protect against whoever controls the running machine: Contabo, which runs the hardware, and us, because we can read the key and sign in to look after the machine. We sign in to your machine only to keep it working and secure, or when you ask us to.
The machine's reports (section 3) say nothing about your projects, your sessions, what you type or what agents produce: they're facts and numbers about the machine, and we drop anything else it sends.

7. Who else handles your data

These companies do work for us and handle your data to do it. Stripe also uses it for its own purposes, such as preventing fraud, and Discord handles your feedback and Dreamer reports as its own controller, each under its own privacy policy:

Company	What they do for Fractal	What they get	Where
Amazon Web Services EMEA SARL (AWS)	Hosting the Portal, sign-in, email, our databases, keys and server functions, and logs	Everything in section 3	Mainly AWS's Ireland region. AWS is part of a US group: the EU-US Data Privacy Framework, and standard contractual clauses
Contabo GmbH	Your Cloud machine	Everything on your machine	The European Union. Contabo is a German company
Stripe Payments Europe, Limited	Taking payments, working out VAT, keeping invoices, and handling disputed payments	Your email address, card, billing address, any VAT number, and what you pay; whether your card is on our block list after a chargeback; and, if you dispute a payment, the evidence for a payment you dispute (section 3)	Ireland. Stripe is part of a US group: the EU-US Data Privacy Framework, and standard contractual clauses
TensorX Ltd	The AI models behind Frack, Rua, Edit with AI, Plan's AI and Research	What you say or type to them, pictures you show them, the Fractal and workflow content they look at to answer you, the text of a brief you ask Plan's AI to read, and Research topics, public source excerpts and selected notes you agree to send	Ireland
Eleven Labs Inc.	Frack and Rua's voices, and their listening	The words of their spoken replies, and recordings of what you say to them	The US: the EU-US Data Privacy Framework, and standard contractual clauses
Cloudflare, Inc.	Reading web pages for Frack, Rua and Research, and passing their web searches to Linkup	The addresses of the pages they read, and the words they search for (logging is off)	The US: the EU-US Data Privacy Framework, and standard contractual clauses
Linkup Technologies SAS	Answering Frack, Rua and Research's web searches, through Cloudflare	The words they search for, which it doesn't keep	France. It may handle searches in the US, Canada or Asia-Pacific
Google Ireland Limited	Google Analytics on our public pages, only if you say yes (section 8)	Which public pages you opened and how you came to them, your browser and device, Google Analytics' own cookie IDs, and your IP address, which it uses to work out roughly where you are and doesn't keep	Ireland. Google is part of a US group: the EU-US Data Privacy Framework, and standard contractual clauses
Discord Netherlands BV	Bringing your feedback, and the Dreamer reports you share, to our team's channel	Your feedback, email address, the page you were on and your browser; and your Dreamer's reports (section 3)	The Netherlands, under Discord's own privacy policy

For a company outside the European Economic Area, the table says what protects your data when it goes there. Email us for a copy.

These you connect yourself, and their own privacy policies cover them:

Anthropic and OpenAI. When Claude Code or Codex works on your machine, it sends your instructions, and the code and files it reads, to Anthropic or OpenAI under your own subscription. We're not part of that.
GitHub. Fractal works in the repositories you choose, with the access you gave it: reading and changing their contents and pull requests, and, if you allowed it, commit statuses. What's in your repositories is on GitHub under your account.

8. Cookies, and what's kept in your browser

Once you're signed in, Fractal uses only what it needs to work, and what remembers your choices. There are no analytics or advertising cookies inside Fractal.

Our public pages (the landing page, pricing and the pages about each application) ask before using Google Analytics. Nothing is set until you say yes, saying no is just as easy, and you can change your mind at any time with Cookie settings at the foot of those pages. Your answer is kept for echofold.ai and every address under it, so you're asked once for Echofold's website and Fractal's public pages together, and again after six months.

Cookie	What it's for	How long
echofold_session, echofold_access, echofold_refresh	Keeping you signed in. Scripts on the page can't read them.	7 days
fractal_totp_challenge, fractal_totp_enrollment	Your authenticator, when you sign in or set one up	3 minutes and 5 minutes
fractal_view	Remembering that you chose the desktop view on a phone	1 year
fractal_cloud_session	Set by your own Cloud machine, so Fractal Code opens inside the Portal	1 hour
echofold_consent	Your answer about analytics on the public pages, and when you gave it. It says nothing about who you are	6 months
_ga and _ga_PEHB62LFRD	Google Analytics, on the public pages, only if you said yes: they tell one visitor from another	2 years, or until you say no

Your browser also keeps some choices itself, until you clear them: the appearance, whether the side rail is folded, where Code runs, which of Frack and Rua are out, where they sit and how big they are, which microphone they use, and whether their voices are on; and your answers in Plan, including the text of any brief you paste or attach, until you start a new plan, sign out, or someone else signs in on that browser (once you hand a plan to Fractal Code, only the first 600 characters of the brief are kept). During sign-up it keeps your email address, name, invitation code and plan for that tab, never your password, and forgets them when the tab closes.

9. How long we keep it

What	How long
Your account, plan, settings, Fractal AI use, boards, workflows and projects	Until your account is deleted (section 10)
An invitation you haven't used	Until it expires, 30 days after it was made
The names of your GitHub repositories	30 days
Stripe's invoices and payment records	Six years, as Irish tax law requires
A card's fingerprint, after a chargeback	Two years from the latest dispute, unless the block is lifted sooner; then it's taken off the block list in Stripe too
Evidence for a payment you dispute	We don't keep a copy. Stripe keeps it with its record of the dispute, under its own privacy policy
Server logs	30 to 365 days, depending on the service; the Portal's, 30 days
AWS's access logs for the Portal	For as long as the Portal is hosted with AWS (section 3)
Copies of our databases, for recovery	35 days
The record of admin changes, by account ID only	As long as we need it to check what was done, and for any legal claim
Feedback	Until your account is deleted, here and in Discord
Dreamer reports you share	Not kept in Fractal's own storage. A posted report stays in the team's Discord channel until we delete it
Emails between you and us	As long as we need them to deal with what you asked, and for any legal claim
What Google Analytics records about the public pages, if you said yes	Up to 14 months in Google Analytics
Your place on the waitlist	Until you unsubscribe from the Echofold newsletter
Your Cloud machine and what's on it, after your plan ends	30 days, then it is wiped

10. Deleting your account

Email support@echofold.ai to ask. Today we pause the account straight away, and delete it 14 days later, or sooner if you ask.
We delete your account's key first, so any of your boards and workflows still left in our database can't be read. Then we delete your plan, settings, projects, boards, workflows, Fractal AI records, billing account, invitation and feedback, and your access to Fractal.
Your Fractal login is deleted with your account. An Echofold login from before 4 November 2026, which still works for Echofold's training site, is separate and is not deleted as part of deleting your Fractal account. Contact support@echofold.ai separately if you want to delete that account too.
We keep Stripe's records for six years, for Revenue; the IDs of Stripe's payment events; the fingerprint of any card blocked after a chargeback, for its two years (section 9), which can still be linked to you through Stripe's records of the dispute; the record of admin changes, which names your account by ID only; and a marker that stops your account ID being used to sign in again.
We also wipe your Cloud machine before anyone else uses it, and remove your GitHub connection. We do both within a month of the deletion.
Copies of our databases are kept for 35 days, so your data is in them until then, your boards and workflows and your account's key included. After 35 days those copies are gone.

11. Your rights

You can ask us:

for a copy of the personal data we hold about you, and to have it in a form you can take elsewhere;
to correct it;
to delete it (section 10);
to limit what we do with it, or to stop, where the law allows.

Email support@echofold.ai. We'll answer within a month, and we may ask you to show the request is really from you. We may ask you to write from your account's email address. A copy of your data comes as a file you can download.

If you're not happy with how we handle your data, you can complain to the Data Protection Commission, at dataprotection.ie.

12. Keeping it safe

Everything between your browser and Fractal is encrypted (HTTPS), and so are our databases.
You can turn on an authenticator for signing in. Admins must have one to open the admin panel.
The admin panel never shows or decrypts your boards, workflows or credentials, or anything from your machine, and every change made in it is recorded.
No system is perfectly safe. If a breach puts your data at risk, we'll tell you and the Data Protection Commission, as the law requires.

13. Children

Fractal is for people aged 18 or over, as the terms say. It isn't for children.

14. Decisions made by computer

Fractal's automatic checks, such as invitation codes and the Fractal AI limits, decide what you can use within your plan. Some checks are automated decisions, made by computer alone: when you pay for a plan, the payment is checked automatically, and if its card was blocked after a chargeback (section 3), the card wasn't issued in the European Economic Area or the UK, or your billing address isn't where Fractal is sold (Ireland, and the UK once we open there), the payment is refused and refunded in full straight away, and your plan doesn't start. A card you add later, in Manage billing, is checked the same way, apart from the billing address: if it was blocked after a chargeback or wasn't issued in the European Economic Area or the UK, it's removed from your account straight away, so it won't pay for your plan, and your plan carries on to the end of the month you've paid for. So is a payment method that isn't a card, since Fractal is paid by card only, and so is any card already on your account when your first payment is checked, straight after it. If you change your billing address in Manage billing to one outside where Fractal is sold, your plan carries on to the end of the month you've paid for, and is set not to renew. Changing it back doesn't renew it: renew your plan in Manage billing to keep it. Stripe may also decline a payment with such a card before it is charged, under rules we set in Stripe. We make these decisions because they're needed to enter into our contract with you, which is only for where Fractal is sold, and to prevent fraud. You have the right to ask for a person to review any of them, to give your point of view and to contest it: email support@echofold.ai. A person at Fractal will look at it, and can lift a card's block if it shouldn't apply, for example if your card was misused by someone else.

15. Changes to this notice

If we change this notice in a way that matters to you, we'll email you. The date at the top says when it last changed.