Privacy Policy
Last updated · July 3, 2026
FAIR is built for founders sharing something sensitive: the fact that you may one day sell your company. We treat that with the discretion it deserves. This policy explains exactly what we collect, why, who processes it, and your rights.
Who we are
The data controller is X23 Capital OÜ (registry code 16927377), Sepapaja 6, 15551 Tallinn, Estonia ("we"), which builds and operates FAIR under its X23 Labs product brand. Contact for anything in this policy: fair@x23labs.com.
What we collect
- Account data — email, name, and a hashed password (we never store the password itself).
- Company briefing — what you tell FAIR so the radar works: company, website, sector, stage, location, target exit range and timeline, what you do, business model, target customers, dream acquirers, competitors, revenue range, core technology. You choose how much to share; some fields are optional.
- Usage data — when you last signed in, which acquirers you watch, and your plan. We run no analytics trackers and build no behavioural advertising profiles.
- Billing data — handled by Stripe. Card details never touch our servers; we store only Stripe customer and subscription identifiers and your plan status.
- Boutique waitlist — if you join the waiting list for our upcoming boutique/advisor product, we store your email and optional firm/role, used only to contact you about that product. Deleted on request.
How we use it
- To run your radar (performance of our contract): scanning M&A activity, scoring acquirers against your briefing, and showing results in your dashboard.
- AI analysis: your briefing is included in prompts to Anthropic's Claude models, which score signals and acquirer fit. Anthropic processes this as our service provider and does not use it to train models.
- Service email (contract / legitimate interest): the weekly digest for paid plans and essential account messages, sent via Resend.
- Security and accountability (legitimate interest): login timestamps and an audit log of any administrative access to accounts.
One company, a strict internal wall
FAIR and X23 Labs are brands of X23 Capital — the same company also provides sell-side M&A advisory services. We are explicit about this because your radar data reveals acquisition intent, and you deserve to know exactly how it is bounded: your FAIR data is used only to operate FAIR. It is never used in, or disclosed to, any advisory engagement or advisory client, and never for any purpose adverse to you. Using it in advisory work would be a different purpose under the GDPR — lawful only with your explicit consent. In practice: if we believe you would benefit from advisory support, we will invite you to a conversation; your data informs advisory work only if you engage us and say yes. All administrative access to your account is recorded in a permanent audit log (see Support access).
At signup you can optionally tick a separate box saying you are open to being contacted about advisory support. It is never required — the product, including the free plan, works identically without it — and you can withdraw it anytime by emailing fair@x23labs.com.
Who processes your data
- Anthropic (USA) — AI analysis of your briefing and market signals. Transfer safeguarded under the EU–US Data Privacy Framework / Standard Contractual Clauses.
- Stripe (USA) — payments. Email and an internal account reference only. DPF / SCCs.
- Resend (EU sending region) — transactional email delivery.
- Hetzner (Germany, EU) — hosting; your data is stored in the EU.
- logo.dev (USA) — your browser fetches acquirer company logos by their domain name; no data about you is sent.
We sell data to no one, and share it with no one else.
Support access
A small number of authorised operators can access account data to run and support the service, including temporarily viewing your dashboard as you see it during a support interaction. Every such access uses a short-lived credential and is recorded in a permanent audit log.
Retention & deletion
We keep your data while your account exists. You can delete your account yourself at any time (Briefing page → Danger zone): your profile, radar, buyers, signals scores and subscription records are permanently removed, and any active subscription is cancelled. Operational logs that contain no briefing data (job history, audit records) are retained for accountability.
Your rights
Under the GDPR (and, where applicable, Brazil's LGPD) you can request access, correction, deletion, portability, or restriction of your data, and object to processing based on legitimate interest — email fair@x23labs.com. You may also lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your local supervisory authority.
Cookies
FAIR sets no cookies and runs no trackers. Signing in stores a session token in your browser's local storage — strictly necessary for the product to work. Details in our cookie statement.
Changes
If this policy changes materially, we will notify you by email before the change takes effect. FAIR is not directed at anyone under 16.
