Napkin AI
Graded against 804 verified platforms, from its own policy text. Automated assessment against a published rubric — not legal advice.
No lens is bandable yet — banding requires fully verified documents with on-criteria findings. The gap is shown honestly, never estimated.
“7.1.3 Where the Customer has not opted out, Napkin AI may use: (a) anonymized and aggregated interaction data, from which all personal identifiers have been removed; and (b) de-identified content data (visual and diagram content from which all personally identifiable information has been removed), solely for the purpose of improving the Services and Napkin…”
Watch: audit rights dpa residency
Start here. These are the highest-risk verified clauses AIRIN found in the platform's own policy text.
Permits Napkin AI to satisfy audit obligations by providing a current SOC 2 Type II or equivalent third-party report as an alternative to a direct audit, conditioned on the Customer agreeing in writing to maintain the report as confidential.
Processing personal data in the U.S. creates compliance obligations for EU/UK/other jurisdiction users under GDPR and similar laws. No mention of transfer mechanisms (SCCs, etc.) is made in this section, which is a notable gap.
This broad transfer clause does not specify which countries data may be sent to or what legal mechanisms (e.g., Standard Contractual Clauses, adequacy decisions) are used to legitimize transfers, which is a gap relevant to GDPR, UK GDPR, and similar frameworks.
How to read this page: Overall risk rates what Napkin AI's own policy terms mean for your prompts, outputs, and data. The benchmark bands below grade those same verified terms relative to peers — a platform in a risky-by-default category can rate HIGH risk and still grade STRONG against its peer set. Both trace to the cited findings.
Fully verified — complete core corpus captured and read in full.
- Privacy PolicyVerified - read in full - 85 citationsstaticLast captured 2026-08-31
- Terms of ServiceVerified - read in full - 173 citationsstaticLast captured 2026-08-17
Only citation-backed plan differences are shown here; absent cells mean AIRIN has not verified a tier-specific claim.
Grants the Customer the right to opt out of all non-essential data use; upon exercise of that opt-out, obligates Napkin AI to process Customer Personal Data solely for service delivery and prohibits use of any Customer interaction data beyond service delivery, with opt-out to be honored within two business days — user-favorable restriction on data use.
" 7.1.2 Napkin AI provides Customers with a mechanism to opt out of all non-essential data use. Where the Customer exercises such opt-out (via Account Settings, Teamspace settings), Napkin AI shall process Customer Personal Data solely to de..."
Defines 'public sources' as a third-party source category including government agencies, public records, and social media platforms from which Napkin may obtain personal information.
" Public sources , such as government agencies, public records, social media platforms, and other publicly available sources."
Grants the Customer the right to opt out of all non-essential data use via Account or Teamspace settings, requiring Napkin AI to process Customer Personal Data solely for service delivery within two business days of the opt-out request.
" 7.1.2 Napkin AI provides Customers with a mechanism to opt out of all non-essential data use. Where the Customer exercises such opt-out (via Account Settings, Teamspace settings), Napkin AI shall process Customer Personal Data solely to de..."
Permits use of personal information for service analytics, improvement of the Service and business, user activity analysis, and development of new products, establishing a broad lawful processing purpose for analytics-driven use.
" Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are..."
Introduces automatic data collection by Napkin, its service providers, and business partners, defining the scope of parties involved and the categories of automatically logged information about users and their devices.
" Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other onli..."
Permits use of personal information for research and development, including creating aggregated, de-identified, or anonymized data derived from personal information, and sharing such data with third parties for lawful business purposes — directly relevant to training use and data transformation rights.
" Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we m..."
Grants the company permission to use personal information to provide, operate, and improve the Service and business, defining a lawful processing purpose.
" provide, operate and improve the Service and our business;"
Discloses that Napkin AI has not received government intelligence or security agency requests for Customer Personal Data and obligates Napkin AI, upon receiving any such future request, to notify the Customer to the extent permitted by law, use reasonable efforts to redirect the agency to request data directly from the Customer, and provide reasonable notice — user-favorable procedural protection.
" 5.5 Government Agency Requests. As of the Effective Date of this DPA, Napkin AI (and Second Layer, Inc.) has not received any formal legal requests from any government intelligence or security agency for access to Customer Personal Data. I..."
Evidence appendix
Showing priority citations first. The full appendix is available for audit trails; not every citation is a severe risk.
" Your profile information may be visible to other users when you collaborate or share content. We do not make your personal information publicly available without your explicit choice to share it."
Restricts the company from making personal information publicly available without the user's explicit choice to share it, while noting that profile information may be visible to collaborators, creating a conditional visibility rule.
AI-generated interpretation, not legal advice.
"We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com ."
Ignoring DNT signals is legal in most jurisdictions but reduces user control over tracking. Some U.S. state privacy laws (e.g., Colorado, Connecticut) require honoring universal opt-out signals, which may create compliance risk for the platform and uncertainty for users.
AI-generated interpretation, not legal advice.
" 11.4 Where fulfilment of a data return or deletion request under Section 11.2 requires manual work exceeding two (2) person-hours, Napkin AI may charge the Customer its reasonable, documented costs at then-current professional services rates, except where such charges are prohibited by Applicable Data Protection Laws."
This clause creates an exception allowing Napkin AI to charge the Customer reasonable documented costs for manual data return or deletion work exceeding two person-hours, except where such charges are prohibited by Applicable Data Protection Laws.
AI-generated interpretation, not legal advice.
" 10.1 Each party’s total aggregate liability to the other party under or in connection with this DPA shall be subject to the liability limitations and caps set out in the Agreement. For the avoidance of doubt, the DPA is part of the Agreement for the purposes of any liability cap."
This clause limits each party's total aggregate liability under the DPA to the caps established in the main Agreement, and incorporates the DPA into the Agreement for purposes of applying those liability caps.
AI-generated interpretation, not legal advice.
"Service providers. Third parties that provide services on our behalf or help us operate the Service or our business, such as: Google Cloud Platform (hosting and infrastructure) Intercom (customer support and communication) Sendgrid and Mailmodo (email delivery) Sentry (error and performance monitoring) Google Analytics (product analytics) OpenAI and Gemini (AI-powered generation and processing services) These service providers process personal data only on our instructions and under strict confidentiality agreements."
Passing user-generated content (including prompts) to OpenAI and Gemini means those providers' own terms and privacy policies may govern how that data is used. Napkin's assertion of 'strict confidentiality agreements' does not eliminate the risk of downstream training or data retention by those providers under their own terms.
AI-generated interpretation, not legal advice.
" Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party."
Restricts retroactive effect of user revocation of third-party platform access rights, clarifying that previously received information from that platform is not subject to the revocation, limiting the scope of the user's opt-out right.
AI-generated interpretation, not legal advice.
" 3.6.2 Napkin AI may satisfy the audit obligations under this Section 3.6 by providing the Customer with a current SOC 2 Type II report or equivalent third-party audit report, subject to the Customer’s written agreement to maintain such report as confidential."
Permits Napkin AI to satisfy audit obligations by providing a current SOC 2 Type II or equivalent third-party report as an alternative to a direct audit, conditioned on the Customer agreeing in writing to maintain the report as confidential.
AI-generated interpretation, not legal advice.
"We are based in the United States and our data is currently hosted on secure cloud infrastructure based in the United States. This means that if you use the Service, your personal information will be transferred to and processed in the United States."
Processing personal data in the U.S. creates compliance obligations for EU/UK/other jurisdiction users under GDPR and similar laws. No mention of transfer mechanisms (SCCs, etc.) is made in this section, which is a notable gap.
AI-generated interpretation, not legal advice.
"We may use service providers that operate in various countries, and your personal information may be transferred to locations where privacy laws may differ from those in your jurisdiction."
This broad transfer clause does not specify which countries data may be sent to or what legal mechanisms (e.g., Standard Contractual Clauses, adequacy decisions) are used to legitimize transfers, which is a gap relevant to GDPR, UK GDPR, and similar frameworks.
AI-generated interpretation, not legal advice.
" 7.1.3 Where the Customer has not opted out, Napkin AI may use: (a) anonymized and aggregated interaction data, from which all personal identifiers have been removed; and (b) de-identified content data (visual and diagram content from which all personally identifiable information has been removed), solely for the purpose of improving the Services and Napkin AI’s AI models (“Model Improvement Processing”). Such use shall not re-identify any individual or Customer."
Permits Napkin AI, where the Customer has not opted out, to use anonymized aggregated interaction data and de-identified content data solely for improving the Services and Napkin AI's AI models, provided no re-identification of any individual or Customer occurs.
AI-generated interpretation, not legal advice.
" Teamspace content: If you create content within a Teamspace, other Teamspace members may have access to that content as determined by the Teamspace Administrator."
Establishes that content created within a Teamspace is accessible to other Teamspace members as determined by the Teamspace Administrator, imposing a data-sharing rule governed by administrator settings.
AI-generated interpretation, not legal advice.
" Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection."
Catch-all provision defining an open-ended category of personal information not otherwise listed, with a forward-reference to uses described elsewhere in the policy, creating a broad definitional scope for data collection.
AI-generated interpretation, not legal advice.
" Device data , such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area."
Defines 'device data' as a specific category of automatically collected personal information including hardware, software, IP address, and location data, specifying the technical scope of device-level data collection.
AI-generated interpretation, not legal advice.
" Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open our emails) – we may do this through the use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails."
Defines 'communication interaction data' as a category of automatically collected data including email open tracking via pixel tags, disclosing the use of tracking technologies embedded in communications.
AI-generated interpretation, not legal advice.
" Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services."
Establishes that providing required personal information is a condition of receiving certain services, and that failure to provide mandatory information may result in inability to provide those services, creating a conditional data-collection obligation.
AI-generated interpretation, not legal advice.
" We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information."
Disclaims any guarantee of security for personal information despite implemented safeguards, acknowledging inherent risk in internet technologies and limiting the company's liability for security breaches.
AI-generated interpretation, not legal advice.
" Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:"
Introduces third-party sources from which Napkin may combine personal information with data collected directly from users, establishing the legal basis for data aggregation and the categories of external sources involved.
AI-generated interpretation, not legal advice.
" Marketing. We, our service providers and our third-party advertising partners may collect and use your personal information for the following marketing purposes:"
Permits the company, its service providers, and third-party advertising partners to collect and use personal information for marketing purposes, identifying the parties involved and the lawful processing purpose.
AI-generated interpretation, not legal advice.
Common questions about Napkin AI's policies
- Does Napkin AI train its AI models on your data?
- Training possible — conditions or opt-outs apply — based on 6 verified findings from Napkin AI's published policy. Informational only, not legal advice.
Clause detail — protections, your obligations, and coverage
Every clause below is a verbatim quote from Napkin AI's own published policy, read in full and linked to its exact location. Protections and user obligations are reported separately from risk because they are different kinds of clause — an obligation on you is not a risk to your data. Informational only, not legal advice.
✅ Protections found
70 verified clausesClauses in Napkin AI's policies that work in your favour — commitments the platform made to you.
- Audit rights, DPA & residency
“12.3 Amendments. Napkin AI may update this DPA from time to time. For changes required by applicable law or that expand privacy protections for Customers, updates take effect immediately upon publication at https://www.napkin.ai/data-processing-agreement/ . Fo…”
This clause establishes the amendment procedure for the DPA, distinguishing between immediate-effect changes required by law or expanding privacy protections and material changes (adding new data categories, new purposes…
- Terms changes: advance notice promised
📍 § 12.3Jump to exact text → - Audit rights, DPA & residency
“5.2 UK Transfers. To the extent that Napkin AI Processes UK Personal Data and transfers such data outside the United Kingdom, the parties agree that such transfers are governed by the UK IDTA. The UK IDTA is hereby incorporated into this DPA by reference, with…”
Incorporates the UK International Data Transfer Agreement into the DPA by reference for UK Personal Data transfers, specifying how each Table of the UK IDTA is completed by reference to existing DPA annexes and the EU SC…
📍 § 5.2Jump to exact text → - Privacy & data usechildren's data
“4.2 The Customer shall be solely responsible for the accuracy, quality, and lawfulness of Customer Personal Data provided to Napkin AI. The Customer shall not submit to the Services any special category personal data (as defined in Article 9 GDPR) or criminal…”
Places sole responsibility on the Customer for accuracy, quality, and lawfulness of Customer Personal Data; restricts submission of special category or criminal conviction data without prior written agreement with Napkin…
📍 § 4.2Jump to exact text → - Subprocessors & data sharinggovernment/law-enforcement disclosure
“5.5 Government Agency Requests. As of the Effective Date of this DPA, Napkin AI (and Second Layer, Inc.) has not received any formal legal requests from any government intelligence or security agency for access to Customer Personal Data. If Napkin AI receives…”
Discloses that no government agency requests for Customer Personal Data have been received as of the Effective Date, and obliges Napkin AI to notify the Customer, redirect government agencies to the Customer, and provide…
📍 § 5.5Jump to exact text → - Subprocessors & data sharing
“3.3.1 The Customer grants Napkin AI general written authorization to engage the Sub-Processors listed in Annex 2 and at https://www.napkin.ai/sub-processors . Napkin AI shall provide at least ten (10) calendar days' prior notice of any intended addition or rep…”
Grants Napkin AI general written authorization to engage listed Sub-Processors and establishes the procedure for notifying the Customer of additions or replacements, including a 10-day advance notice requirement and subs…
📍 § 3.3.1Jump to exact text → - Subprocessors & data sharingsale/sharing of personal data
“8.2 Service Provider Designation. For purposes of the CCPA/CPRA, Napkin AI is a “service provider” and “contractor” with respect to Customer Personal Data. Napkin AI shall not: (a) sell or share Customer Personal Data (as those terms are defined under CCPA/CPR…”
This clause designates Napkin AI as a 'service provider' and 'contractor' under CCPA/CPRA and imposes specific restrictions prohibiting Napkin AI from selling, sharing, retaining, using, or disclosing Customer Personal D…
📍 § 8.2Jump to exact text →
+ 64 more verified clauses of this kind on this platform, cited in full in the report.
📋 Rules you must follow
1 verified clauseWhat Napkin AI requires of YOU. These are your obligations, not risks to your data or IP, so they are cited here and excluded from this platform's risk rating.
- Moderation & enforcement
“4.3 The Customer shall implement appropriate technical and organizational measures to secure Customer’s own systems, credentials, and any software integrations used to access the Services.”
Obliges the Customer to implement appropriate technical and organizational measures to secure its own systems, credentials, and software integrations used to access the Services.
📍 § 4.3Jump to exact text →
What the policies actually cover
14 topics- Product telemetry & usage tracking17 clauses
- Advertising & tracking1 protective8 clauses
- Sale or sharing of personal data2 protective2 clauses
- Sensitive data (biometric, location, health)1 clause
- Children's data2 protective2 clauses
- Government & law-enforcement disclosure1 protective4 clauses
- Data shared with other AI providers2 protective4 clauses
- Does not train on your content3 protective3 clauses
- Trains by default, opt-out available1 clause
- Damages & liability cap1 protective3 clauses
- Indemnity direction4 protective8 clauses
- Terms can change at any time1 clause
- Deletion rights & post-termination survival3 protective8 clauses
- Breach-notification promises7 protective8 clauses
188 further verified clauses are cited on this page but not yet assigned a topic.
Cross-clause notes
Two verified clauses intersect on the same subject matter: the Terms of Service, § 11.4 addresses how long content is retained, and the Terms of Service, § 7.1.3 addresses use of content in connection with model training or service improvement. Both clauses are in force at the same time — read them together.
Verified retention clauses point in different directions: the Privacy Policy, Privacy Policy › “Retention” describes broad or open-ended retention, while the Terms of Service, § 11.4 describes deletion or erasure. Which clause controls in a given situation is not resolved by the documents' text alone — this is surfaced as an ambiguity, treated as Caution.
Automated cross-reference against the published rubric — not legal advice.
Clause intelligence
Canonical clauses and stance patterns extracted from the same gate-verified citations shown on this page.
The clause allows indefinite, perpetual, or necessity-based retention.
“We generally retain information for as long as necessary to provide the service, to fulfill the purposes outlined in this Privacy Policy, to comply with legal, accounting, contractual, or operational obligations, to establish or defend legal claims, or to prevent fraud. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the...”Open source citation
The clause allows indefinite, perpetual, or necessity-based retention.
“We generally retain information for as long as necessary to provide the service, to fulfill the purposes outlined in this Privacy Policy, to comply with legal, accounting, contractual, or operational obligations, to establish or defend legal claims, or to prevent fraud. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the...”Open source citation
The clause allows indefinite, perpetual, or necessity-based retention.
“We generally retain information for as long as necessary to provide the service, to fulfill the purposes outlined in this Privacy Policy, to comply with legal, accounting, contractual, or operational obligations, to establish or defend legal claims, or to prevent fraud. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the...”Open source citation
The clause allows indefinite, perpetual, or necessity-based retention.
“We generally retain information for as long as necessary to provide the service, to fulfill the purposes outlined in this Privacy Policy, to comply with legal, accounting, contractual, or operational obligations, to establish or defend legal claims, or to prevent fraud. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the...”Open source citation
The clause allows indefinite, perpetual, or necessity-based retention.
“We generally retain information for as long as necessary to provide the service, to fulfill the purposes outlined in this Privacy Policy, to comply with legal, accounting, contractual, or operational obligations, to establish or defend legal claims, or to prevent fraud. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the...”Open source citation
Tier matrix
Plan-level conditions detected from citation-backed clauses. Empty tiers mean AIRIN has not captured decisive tier language yet.
| Tier | Surface | Verdict | Risk | Citations |
|---|---|---|---|---|
| All applicable tiers | data retention | conditional | MEDIUM | 5 |
| All applicable tiers | indemnity liability | conditional | MEDIUM | 1 |
| All applicable tiers | privacy data use | conditional | MEDIUM | 19 |
| All applicable tiers | subprocessors data sharing | conditional | MEDIUM | 4 |
| All applicable tiers | training use | improves | LOW | 4 |
| Team / Business | data retention | worsens | HIGH | 2 |
| Team / Business | moderation enforcement | worsens | HIGH | 1 |
| Team / Business | privacy data use | worsens | HIGH | 9 |
| Team / Business | subprocessors data sharing | conditional | MEDIUM | 1 |
| Team / Business | tier differences | conditional | MEDIUM | 1 |
| Team / Business | training use | conditional | MEDIUM | 3 |
Policy evolution
Open full timelineBefore/after stance changes across captured policy versions. When no material delta exists yet, AIRIN shows the latest citation-backed stance events instead.
data sharing improved from high/sale or sell to medium/third party or vendor sharing.
“8.2 Service Provider Designation. For purposes of the CCPA/CPRA, Napkin AI is a “service provider” and “contractor” with respect to Customer Personal Data. Napkin AI shall not: (a) sell or share Customer Personal Data (as those terms are defined under CCPA/CPRA); (b) retain, use, or disclose Customer Personal Data for any purpose other than the business purposes specified in this DPA and the Agreement; or (c) combine Customer Personal Data received from the Customer with personal information received from other sources except as permitted by U.S. Privacy Laws.”Before citation
“We may use service providers that operate in various countries, and your personal information may be transferred to locations where privacy laws may differ from those in your jurisdiction.”After citation
data sharing worsened from medium/third party or vendor sharing to high/sale or sell.
“Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, such as when you share content with collaborators, or connect third-party services. We only share information that is needed for these other companies to provide the services that you have requested.”Before citation
“8.2 Service Provider Designation. For purposes of the CCPA/CPRA, Napkin AI is a “service provider” and “contractor” with respect to Customer Personal Data. Napkin AI shall not: (a) sell or share Customer Personal Data (as those terms are defined under CCPA/CPRA); (b) retain, use, or disclose Customer Personal Data for any purpose other than the business purposes specified in this DPA and the Agreement; or (c) combine Customer Personal Data received from the Customer with personal information received from other sources except as permitted by U.S. Privacy Laws.”After citation
model training improved from high/training permitted to low/no training claim.
“We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.”Before citation
“NOTE RE: AI SUB-PROCESSORS – ZERO DATA RETENTION: Napkin AI maintains zero-data-retention (ZDR) agreements with all AI inference sub-processors (currently Google Cloud AI and OpenAI). Customer Personal Data submitted to these providers is not retained beyond the immediate processing request and is not used for model training by those providers.”After citation
Latest stance: third party or vendor sharing on privacy data use
“We may use service providers that operate in various countries, and your personal information may be transferred to locations where privacy laws may differ from those in your jurisdiction.”Open timeline citation
Latest stance: third party or vendor sharing on privacy data use
“These service providers process personal data only on our instructions and under strict confidentiality agreements.”Open timeline citation
Latest stance: indefinite or necessity based on data retention
“We generally retain information for as long as necessary to provide the service, to fulfill the purposes outlined in this Privacy Policy, to comply with legal, accounting, contractual, or operational obligations, to establish or defend legal claims, or to prevent fraud. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.”Open timeline citation
Latest stance: third party or vendor sharing on privacy data use
“Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, such as when you share content with collaborators, or connect third-party services. We only share information that is needed for these other companies to provide the services that you have requested.”Open timeline citation
Capture recency
- Privacy Policy:Last captured 2026-08-31· verified 2026-08-31
- Terms of Service:Last captured 2026-08-17· verified 2026-08-17
Dates state when our pipeline captured and verified each document — not when the vendor last changed it. Documents are re-scanned on a recurring cadence; a document verified once says so until a re-scan confirms it again.
↑ 211 more findings this quarter vs last (453 vs 242). First scan: June 2026.
Compare and stack are saved in your browser. Open compare · View your stack. A correction triggers an automated re-read of Napkin AI's policies — no human edits the data.
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Every finding above is a verbatim quote from Napkin AI's own published policy, captured to an immutable snapshot and read in full through a two-gate verification pipeline. Confidence labels and any analysis are AI-generated and informational only — not legal advice.
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