DRAFT — not reviewed by a lawyer.
Privacy policy
Last changed: 2026-11-03 (draft).
CommandAGI Inc. ("we"), sells exocortex and runs my-exocortex.com and its API. This policy says what personal data we receive, why, where it goes, and how you can get it or have it deleted.
The short version
- The app is local-first. What the helmet and the app record (EEG, camera frames, sound, transcripts, your imported messages and mail, your notes, the app's interpretations) is stored on your own computer. We do not receive it, and we cannot read it.
- We receive only what we need to sell you a helmet and run your account: your name, email, phone, shipping and billing addresses, your order, and your sign-in records.
- We do not sell personal data, and we do not share it for advertising. We have no advertising and no analytics trackers on the site.
- Neural data gets the strictest treatment we offer, whether or not a law requires it (§ neural data).
1. What we receive
| data | when | why | where it is kept | how long |
|---|---|---|---|---|
| name, email, phone, shipping and billing address, quantity, amount, time, Stripe customer id | you pre-order or buy | to make, ship and support your order; tax and accounting records | Stripe; our order store (Cloudflare Workers KV, api/src/orders.js) |
7 years after the sale for tax records, then deleted |
| card or bank details | you pay | payment | Stripe only. We never see the full card number | Stripe's policy |
| email address, the name you give, passkey public keys, sign-in records (a SHA-256 of each token, the device's user agent, times), the apps you signed in, the link to your pre-orders | you create or use an account | to sign you in, keep your account secure, and show your orders | Cloudflare D1 | until you delete the account; expired sessions are removed |
| emails you send us, support tickets, RMA details | you contact support | to answer you and repair or replace units | our support mailbox (provider not chosen yet) | 3 years after the ticket closes |
| IP address, browser type and the page requested | you visit the site or call the API | to deliver the page and protect the service | Cloudflare's logs | Cloudflare's retention |
We do not receive EEG, video, audio, location or imported data unless you send it to us yourself (for example, a recording attached to a support ticket). If you do, we use it only to answer that ticket, and delete it when the ticket closes.
2. What stays on your computer
The exocortex app runs one "node" on your computer: the exocortex daemon or the desktop app
(app). It stores, in its data folder on your computer:
- EEG from the helmet: the raw frames and per-second summaries;
- camera frames from the five cuff cameras, and photos from a paired phone;
- sound you dictate, and its transcript (transcribed on your computer by an on-device model);
- location fixes from a paired phone, if you turn that on;
- imported data: exports you choose from ChatGPT, Claude, X, LinkedIn, Google, email, calendars, Notion, Meta, Discord, Slack, Telegram, Reddit, WhatsApp and others;
- interpretations: the app's guesses about the above, each linked to what it read.
The helmet sends EEG to your computer over USB or your own Wi-Fi, and each camera streams to your computer over your Wi-Fi. None of it passes through our servers. A phone you pair with your computer talks to it directly on your local network, encrypted with a key only the two devices hold (sync).
You control what leaves your computer. The app sends data out only when you turn on something that does so:
- a cloud model (an OpenAI-compatible API with your own key): the questions you ask and the events the agent may read go to that provider, under its terms;
- a connector (for example a webhook to Slack): what that connector's skill sends;
- the external-agent API: someone you give a token to can ask questions about the slice of your data you expose, and every question is logged in your stream.
Each is off until you turn it on, and the app shows what it would read and where it would go before you connect it. The app sends us no telemetry and no crash reports. When you sign the app in to your account, it holds a read-only token for your account, and nothing from its store is sent to us.
3. Neural data
EEG is neural data: it can reveal things about your health and your mind. We treat it this way:
- We do not collect it. It stays on your computer by design.
- If you ever send it to us (a support ticket, a research study you join), we use it only for the purpose you sent it for, we ask for your explicit consent first, and we delete it when that purpose ends.
- We never sell it, never use it for advertising, and never use it to train models unless you agree to that in a separate, specific consent that you can withdraw.
- Any future feature that sends neural data off your computer will be off by default and will ask first.
Neural-data law. Several US states treat neural data as sensitive personal data: Colorado (HB 24-1058, 2024), California (SB 1223, 2024, in the CCPA), Montana (SB 163, 2025) and Connecticut (SB 1295, 2025). Washington's My Health My Data Act covers consumer health data with no size threshold. In the EU and the UK, EEG data can be health data and biometric data under GDPR Article 9. Because we do not collect neural data, most of these laws' duties on collection do not arise; where we do receive it (above), we follow the strictest of them: opt-in consent, purpose limits, deletion on request.
California (CalOPPA). This policy is linked from every page of the site. We do not respond to browser "Do Not Track" signals differently, because we do not track you across sites at all.
4. Who else processes data for us
| company | what for | data |
|---|---|---|
| Stripe | payments, checkout, refunds | name, email, phone, addresses, payment details |
| Cloudflare | hosting the site and the API, the order and account stores, sending sign-in email | the order and account data above, request logs |
| the shipping carrier | delivery | name, address, phone |
| the support mailbox provider | support email | your messages |
The site also loads fonts from Google Fonts and a 3D library from jsDelivr, so your browser sends your IP address to those services when a page loads.
We share personal data with others only when the law requires it, or to protect someone's safety, and we tell you when the law allows us to.
5. Your rights: export and deletion
- The app: your data is in the app's data folder (app § run it). Copy the folder to export it; it is plain JSON-lines and files. Delete the folder to delete it. Unpairing a phone wipes the phone's key, cache and outbox.
- Your account: on the account page you can download everything the account holds as one JSON file, change your name, remove passkeys and signed-in apps, and delete the account. Deleting the account deletes its sign-in data at once.
- Your orders: email the support address on your Stripe receipt from your order's address to get a copy, correct it or delete it. We answer within 30 days. We keep what tax law requires (§ 1) and delete the rest.
- Depending on where you live (for example the EU, the UK, California, Colorado), you have further rights: to object, to restrict processing, to complain to your data-protection authority. We honour them for everyone, wherever you live.
6. Security
Tokens are stored only as hashes. Paired phones use per-device keys and encrypt every request. The app's API listens only on your computer's loopback address. Report a vulnerability to the support address on your Stripe receipt.
7. Children
exocortex is for people 18 and older. We do not knowingly take orders or accounts from anyone younger.
8. Transfers
We are in the United States, and our processors may handle data in other countries.
9. Changes and contact
We will email account holders before a change that reduces their privacy takes effect. Contact: the support address on your Stripe receipt, or CommandAGI Inc..