1. Overview

This Privacy Policy explains what data Moguls Inc ("we", "us", "our") collects through the Cuttlefish website (getcuttlefish.app) and the Cuttlefish desktop application (the "App"), and how that data is used, stored and kept.

Cuttlefish is offered to organizations, and people use it through their organization's account. Some of what the App does happens only on your device. Some data passes through our hosted services, and some is stored there with your account. Sections 3 and 4 say which. The roles of Moguls Inc and your organization are set out in our data processing terms.

2. What the Website Collects

Server logs

When you visit getcuttlefish.app or app.getcuttlefish.app, request metadata such as IP address, browser user-agent, requested path, and timestamp may be processed by our hosting and edge providers for routing, availability, caching, and security operations. The public website and mobile PWA are hosted by Amazon Web Services and delivered through Amazon CloudFront.

Website analytics

Cuttlefish may collect first-party operational website analytics to understand page views, navigation, download clicks, installer delivery, update activity, and product health. These analytics are used internally for reliability, installation proof, and product planning. They do not include advertising cookies, cross-site behavioral tracking, prompts, model outputs, credentials, or customer content.

No tracking cookies

The Cuttlefish website does not set tracking cookies, advertising cookies, or third-party analytics cookies. First-party website analytics use privacy-preserving browser storage and sanitized event metadata. We do not use Google Analytics, Facebook Pixel, or any similar tracking technology.

3. What the Desktop App Collects

When you sign in to the App, the following data is sent to our hosted services, and in most cases stored there with your account:

• Account and organization information — your name, email address, organization, role, and the sign-in identity you use. For your organization's subscription, we also keep the billing contact details in its order.
• Conversation history — the prompts and responses in your conversations are saved to your Cuttlefish account in our hosted services, so your history is available on your devices. This includes conversations with models you run on your own machine. The titles and messages of your conversations are also sent to a context service in our hosted services that helps Cuttlefish keep track of your ongoing work.
• Memories — facts Cuttlefish learns to remember about your work are sent to our hosted memory service and saved with your account. Automatic memory extraction can be turned off in Settings.
• Cloud model provider keys — when you connect a cloud AI provider, its API key is sent over an encrypted connection to our credential service and stored encrypted (AES-256-GCM), so the requests you start with that provider can run. Keys for models you run on your own machine stay in your operating system's keychain.
• Requests to cloud models — when you use a cloud AI provider, your prompts and the model's responses are relayed through our hosted services to that provider, using your own key.
• Screen images — the App can capture an image of your screen, of one window, or of a region you select: when you draw a region with the capture shortcut, when an agent uses its screen or window capture tools, and before and after desktop or browser actions it carries out for you. The image is reduced in size and sent with the conversation to the AI model you are using. A model on your own machine processes it there. With a cloud provider, it is relayed through our hosted services to that provider. Our hosted services keep only a reference to an image in your conversation history, not the image itself, with one exception: screenshots that desktop automation takes before and after an action can be saved, in whole or in part, in the record of that action in your conversation history. Region capture can be turned off in Settings. Captures made by agents and around the actions they carry out are part of the tasks you ask Cuttlefish to do and cannot currently be turned off separately.
• File content — your files stay on your local filesystem. When a model reads part of a file for you, that content becomes part of the conversation: it is sent to the cloud provider if you are using one, and it is saved with your conversation history.
• Session metadata — session identifiers, timestamps, and configuration preferences necessary to operate the App.
• Governance receipts — cryptographically signed records of the policy checks Cuttlefish performs before consequential actions, stored in write-once storage. See Section 5.
• Update checks — the App periodically contacts our update server to check for new versions. This request includes your current app version and operating system.

4. What Stays on Your Device

• Keys for on-device models — API keys for models that run on your own machine are stored in your operating system's keychain (macOS Keychain, Windows Credential Manager, or Linux Secret Service) and are not sent to our servers.
• Processing by on-device models — when you use a model you run on your own machine, your prompts and its answers are processed there and are not sent to any AI provider. The conversation is still saved to your account as described in Section 3.
• Captured images — captured images are kept in the App's data on your device, and browser actions your organization requires evidence for are saved there as image files. The App does not delete these images automatically; they stay until they are removed from your device.
• Keystrokes — the App does not include any keylogging functionality.
• Location data — the App does not request or collect geolocation information.

Note: when you use third-party AI providers (OpenAI, Anthropic, etc.) through Cuttlefish, your prompts are relayed through our hosted services to those providers using your own API keys. The providers' handling of that data is governed by each provider's own privacy policy. See our subprocessors page and the data processing terms for how third-party data sharing is handled.

5. Governance Receipts and 7-Year Retention

Before Cuttlefish takes a consequential action, it records a cryptographically signed receipt of the policy check it performed. These receipts are stored in write-once, read-many storage with a 7-year retention period, and their signatures make them tamper-evident.

Governance receipts contain:

• Policy evaluation outcomes (allow / deny decisions)
• Timestamps and session identifiers
• Cryptographic signatures for tamper-evidence

Governance receipts record policy and action metadata rather than raw provider credentials. Separate conversation records and supporting action evidence can contain task content, including file excerpts or screenshots, as described in Section 3. Access and retention depend on the record category.

The 7-year retention period is designed for regulatory compliance and audit trail integrity. Receipts cannot be modified or deleted during this period. For how these records relate to data sharing and processing roles, see our data processing terms.

6. How Long We Keep Data

We do not currently delete stored data automatically after a set period. Data is kept as follows:

• Account information — kept while your account is active. When you delete your account in Settings, the account is marked deleted and your sign-in sessions are revoked.
• Conversation history — kept with your account. When you delete a conversation in the App, it is removed from your history and our service stops returning it, but the stored record is marked deleted rather than erased at that time. Deleting your account does not currently erase stored conversation history.
• Memories and conversation context — kept with your account.
• Cloud model provider keys — kept until you remove the connection in Settings, which erases the stored key. Deleting your account marks your connections deleted.
• Governance receipts — kept for 7 years, as described in Section 5.
• Data on your device — stays on your device until it is removed there.

To have stored conversations, memories, keys or other account data erased from our hosted services, contact legal@getcuttlefish.app. Governance receipts are kept for their retention period.

7. Third-Party Services

Cuttlefish integrates with the following categories of third-party services:

• AI providers (OpenAI, Anthropic, Mistral, etc.) — prompts are relayed through our hosted services to these providers using your own API keys. Prompts to models you run on your own machine are not sent to any AI provider.
• Amazon Web Services (AWS) — hosts our hosted services, the public website and the mobile PWA, with global edge delivery through Amazon CloudFront. Subject to the AWS Privacy Notice.
• Microsoft Azure — holds retained storage and backups from our former hosting of the Cuttlefish service. That former system is disabled and no longer runs the service, and the retained data has not been erased.

Founders purchasing is arranged with our team. No payment processor currently handles customer data for Cuttlefish; before one does, it will be added to our subprocessors page. For the maintained list of the providers that process data on our behalf, see our subprocessors page. Data processing roles and responsibilities are set out in our data processing terms.

8. Data Storage and Security

Our hosted services run on Amazon Web Services (AWS) in the United States. Storage and backups from our former hosting on Microsoft Azure, also in the United States, are still retained; that former system is disabled and does not run the service. Data at rest is encrypted. Data in transit uses TLS 1.2+.

Governance receipts are stored in immutable, write-once blob storage with signature verification to ensure tamper-evidence.

For more details on our security practices, see our Security Policy.

9. Your Rights (GDPR / CCPA)

For EU/EEA residents (GDPR)

If you are located in the European Economic Area, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data (subject to the write-once retention policy for governance receipts)
• Object to or restrict processing of your data
• Data portability
• Withdraw consent at any time

For California residents (CCPA)

If you are a California resident, you have the right to:

• Know what personal information is collected about you
• Request deletion of your personal information
• Opt out of the sale of personal information — we do not sell personal information
• Non-discrimination for exercising your rights

To exercise any of these rights, contact us at legal@getcuttlefish.app. Erasure of conversation history and other stored data from our hosted services is carried out by our team on request, as described in Section 6.

10. Children Under 13

Cuttlefish is offered to organizations and is not intended for use by children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact us at legal@getcuttlefish.app and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. For material changes, we will provide notice through the application or website. Your continued use of Cuttlefish after changes constitutes acceptance of the updated policy.

12. Contact

For privacy-related questions or to exercise your data rights:

Moguls Inc
Email: legal@getcuttlefish.app
Support: support@getcuttlefish.app
Admin: admin@getcuttlefish.app
Web: https://getcuttlefish.app