Last updated: 12 July 2026
Your brain is yours. Each tenant's memory graph runs in its own isolated database. We don't read, mine, sell, or train on the contents of your graph. We touch it only to run and back up the Service for you, or when you ask us to. We process personal data in accordance with the Kenya Data Protection Act, 2019, and honour equivalent rights for users elsewhere.
Brainbox ("the Service") is operated by CIF AI Holdings Limited (company no. PVT-L51DY5MR), a private limited company incorporated in the Republic of Kenya under the Companies Act, 2015, trading as thexi.dev ("we", "us", "our"). CIF AI Holdings Limited is the data controller for your account data. For any privacy question, contact privacy@thexi.dev. Registered office: Serengeti Homes, Kongoni 9B, Ngong Road, Kileleshwa, Nairobi, Kenya; postal address P.O. Box 12168, 20100 Nakuru, Kenya.
Our legal bases (Kenya DPA 2019 s.30, and GDPR/UK-GDPR where they apply) are: performance of our contract with you, your consent — which storing content in your brain expresses and which you may withdraw by deleting it — and our legitimate interest in operating and securing the Service.
AI processing: to make your brain searchable and to distil session summaries, your content is processed by machine-learning models run by our infrastructure providers (currently Cloudflare Workers AI; AWS for optional answer generation). They process it only to serve your requests — we do not permit your content to be used to train models, ours or anyone else's.
Brainbox runs on infrastructure operated by our sub-processors:
| Provider | Role | Location |
|---|---|---|
| Amazon Web Services (AWS) | Compute, identity (Cognito), your isolated tenant database, encrypted nightly backups (S3) | United States (us-east-1) |
| Cloudflare | Edge network & tunnel, the MCP/API service (Workers), AI processing (Workers AI), this dashboard (Pages) | Global edge |
Cross-border transfer: your account email and graph are stored in the United States (AWS us-east-1). Under s.48–49 of the Kenya DPA we apply appropriate safeguards for this transfer — per-tenant isolation, encryption in transit (TLS) and at rest, contractual data-protection commitments from the providers above — and by using the Service you consent to it.
Your brain is backed up nightly: a full, consistent database snapshot is written to encrypted object storage (AWS S3) under your tenant's own prefix, via a write-only path. Backups are retained on a 30-day rolling window and expire automatically — retention is enforced by the storage layer itself, not by a script that could fail.
Under the Kenya Data Protection Act, 2019 (s.26) — and equivalent laws elsewhere — you have the right to be informed, to access, to correction, to deletion, to object, and to data portability. Concretely:
| Data | Lifecycle |
|---|---|
| Live memory graph | Kept while your account is active; every item individually deletable by you, effective immediately. |
| Superseded memories | When new information replaces old, the old memory is kept, marked superseded and down-ranked — your history stays honest — until you delete it. |
| Backups | Nightly snapshots, 30-day rolling expiry. |
| Operational logs | Minimal request/error metadata, short-lived, never mined. |
| After account deletion | Live data + credentials destroyed within 72 hours; nightly backups fully aged out within 30 days; one final safeguard snapshot purged at 90 days. |
Per-tenant database isolation, identity-verified access (Cognito RS256 id-tokens), no inbound ports on the node (admin only via AWS SSM), per-tenant database secrets that never leave the host, and per-tenant usage quotas. No system is perfectly secure, but isolation is a first-class design goal.
If a breach affecting your personal data occurs, we will notify the ODPC within 72 hours of becoming aware of it and notify you without undue delay, as the Kenya DPA requires.
The Service is not directed at children under 16, and we don't knowingly collect their data.
We'll post changes here and update the date above. We'll notify you of material changes by email.