This Privacy Policy explains how Virsabi ApS ("Virsabi", "we", "us")
collects, uses, and protects information when you use the Xpert AI mobile
application and related services (the "Service"). Xpert AI is a professional tool that creates
AI assistants from product manuals and lets you ask questions about equipment using your phone
camera, your voice, and optionally Ray-Ban Meta smart glasses.
Xpert AI is a business-oriented product offered as a free trial that can later convert to a paid
enterprise plan arranged directly with our sales team. There are no in-app purchases.
1. Who is responsible for your data
The data controller for the Service is: Virsabi ApS
Bredgade 28B, 2., 1260 København K, Denmark
Company reg. no. 38283146
Privacy contact: support@virsabi.com
When Xpert AI is used by an enterprise customer, that customer may act as the data controller
for content processed within their tenant, and Virsabi acts as their data processor under a
data processing agreement (DPA).
2. Information we collect
Account information
Sign in with Apple identifier. When you create a free account we receive a
stable, Apple-provided account identifier and (if you choose to share it) an email address.
We use this to create and identify your account and to contact you about the Service. We do
not receive your Apple password.
Enterprise access keys. Enterprise and beta users may instead sign in with
an access key issued by us; this links the app to your organization's tenant.
Content you provide
Camera images / video frames captured when you point your phone (or glasses)
at a product, used to provide visual guidance.
Voice audio when you speak to an assistant, converted to text so we can
understand your request.
Text and questions you type or speak to an assistant.
Knowledge-base documents (e.g. product manuals) associated with the
assistants you create.
Expert call media — if you start a live call with a human expert, real-time
audio and video are exchanged between participants.
Usage and technical data
Operational counters needed to enforce free-plan limits (for example, the number of questions
asked in a 24-hour period, assistants created, and expert calls used).
Basic technical logs (request identifiers and tenant identifiers) used for reliability and
abuse prevention. We do not write the content of your images or messages to these logs.
3. How we use your information
To provide the core functionality: identify products, generate assistants, answer your
questions, and transcribe your voice.
To create, secure, and manage your account, and to enforce free-plan usage limits.
To enable optional live expert calls.
To communicate with you about the Service, support requests, and (for trial accounts) to
follow up about enterprise plans.
To maintain reliability and prevent abuse.
We do not sell your personal data, and we do not use your camera images, voice,
or chat content to train our own advertising or unrelated models.
4. AI sub-processors and where data is processed
To deliver the Service we share specific content with the sub-processors below. The processor
used for AI vision and chat depends on the model assigned to your plan (free accounts use Google
Gemini; enterprise tenants may be configured for EU-only processing via Azure OpenAI).
Data
Purpose
Processor / region
Stored by us?
Camera images / frames, chat text
AI vision & chat completion
Anthropic (US) or Google Gemini (US) or Azure OpenAI (West Europe, EU) — depending on plan
No — transient
Voice audio
Speech-to-text transcription
Deepgram (US)
No — transient
Knowledge-base documents
Stored and supplied to the AI as context
Microsoft Azure Cosmos DB (North Europe, EU)
Yes — EU
Account & tenant metadata
Account provisioning
Microsoft Azure Cosmos DB (North Europe, EU)
Yes — EU
Expert call audio/video
Live peer-to-peer expert calls
Cloudflare TURN (global relay, when direct connection is not possible)
No — not persisted
Expert notification (SMS)
Notify an expert of an incoming call
Microsoft Azure Communication Services (Europe)
Per provider
International transfers. Our data storage is located in the EU (North Europe).
However, if your plan uses the Anthropic (Claude) or Google (Gemini) models, or for voice
transcription (Deepgram), the relevant content is processed in the United States.
These transfers are covered by appropriate safeguards (e.g. Standard Contractual Clauses).
Enterprise customers who require EU-only processing can be configured to use the Azure OpenAI
(West Europe) path. Contact support@virsabi.com for details.
5. Legal basis for processing (EEA/UK)
Performance of a contract — to provide the Service you request.
Legitimate interests — to secure the Service, prevent abuse, and, for trial
accounts, to follow up about enterprise plans.
Consent — for device permissions such as camera and microphone, which you
grant in iOS and can withdraw at any time in Settings.
6. Data retention
Conversations are kept on your device only and are not stored on our servers.
Knowledge-base documents and account metadata are retained for as long as
your account is active.
Expert sessions and rate-limit counters expire
automatically (short-lived).
When you delete your account, your tenant data is purged (see below).
7. Your rights and choices
Depending on your location, you may have the right to access, correct, export, or delete your
personal data, and to object to or restrict certain processing.
Delete your account. You can delete your account and associated data at any
time from within the app: Settings → Delete Account. This permanently removes your
tenant and its stored data.
Device permissions. You can revoke camera, microphone, speech, and Bluetooth
access at any time in the iOS Settings app.
Requests. To exercise any other right, contact
support@virsabi.com. You also have the right to lodge a
complaint with your local data protection authority.
8. Children
Xpert AI is a professional tool intended for use by adults in a work context. It is not directed
to children, and we do not knowingly collect personal data from children.
9. Security
We use per-tenant data isolation, bearer-key/session authentication, encrypted transport (HTTPS),
and EU-based encrypted storage. No method of transmission or storage is completely secure, but we
work to protect your information using industry-standard measures.
10. Changes to this policy
We may update this policy from time to time. Material changes will be reflected by updating the
"Last updated" date above and, where appropriate, by notice within the app.