Privacy Policy

Last updated: 2/9/2026

This Privacy Policy explains how FatCat Capital Ltd. processes personal data in connection with SecondLayer.

Data We Process

We process only the minimum data necessary to operate the Service, including:

• session identifiers
• usage and quota information
• feature interaction metadata

Submitted Content

Text submitted to the Service is processed to generate analysis. We do not sell submitted content or use it for advertising. Content may be temporarily stored for operational and security purposes.

Account Information

If you create an account, we may process your email address and subscription status. Payment information is handled exclusively by third-party payment providers.

Purpose of Processing

Personal data is processed solely to:

• provide and maintain the Service
• enforce usage limits
• ensure security and reliability

Legal Basis (GDPR)

Processing is based on legitimate interests in operating the Service and, where applicable, contractual necessity or user consent.

Data Sharing

We do not sell personal data. Data may be shared only with infrastructure and service providers strictly necessary to operate SecondLayer.

Retention

Data is retained only for as long as necessary for operational, security, or legal purposes.

Your Rights

Under applicable data protection laws, you may have rights to access, rectify, or delete your personal data.

Security

We implement reasonable technical and organisational measures to protect data. However, no system can be guaranteed to be completely secure.

Governing Law

This Policy is governed by the laws of Ireland.

Contact

Data Controller: FatCat Capital Ltd.
Email: support@fatcat-capital.com