Records of processing activities

1. Controller and contact

Controller: Needs legal reviewlegal entity name, registered address, company registration number. Privacy contact: Needs legal reviewprivacy contact email. Representative and DPO, where applicable: Needs legal reviewconfirm whether a DPO or EU representative is required

2. Processing activities as controller

• Workspace user accounts — purpose: providing and securing the service (contract, legitimate interest). Data: name, email, password hash, two-factor secrets, session and device data. Retention: deleted Needs legal reviewperiod after account closure.
• End-customer conversations — purpose: delivering assistant answers on behalf of the business operating the assistant (we act as processor; the business is the controller). Data: channel identifiers (e.g. phone number, Telegram user ID, widget session) and message content. Retention: Needs legal reviewconversation retention period.
• Pseudonymization vault — purpose: keeping raw end-customer personal data out of AI model calls and logs (legal obligation and legitimate interest in data minimisation). Data: original values replaced by tokens before model calls. Retention: each entry carries a purge date and is deleted automatically by retention jobs, after 30 days at the latest. Needs legal reviewconfirm the purge window with legal counsel
• Contact-form submissions — purpose: responding to enquiries (legitimate interest, steps towards a contract). Data: name, email, message. Retention: purged automatically after 90 days. Needs legal reviewconfirm the purge window with legal counsel
• Audit and security logs — purpose: security, abuse prevention and accountability (legitimate interest, legal obligation). Data: actions performed in the dashboard and administrative events; never raw message bodies. Retention: append-only; pseudonymized on erasure. Needs legal reviewaudit-log retention period
• Billing and usage records — purpose: enforcing plan limits and, once billing is active, invoicing (contract, legal obligation). Data: usage counters and subscription state. Needs legal reviewbilling provider, data and retention once payments are introduced

3. Recipients and transfers

Recipients are the sub-processors listed on the Sub-processors page. Personal data is processed in the EU; any transfer outside the EU relies on an adequacy decision, the EU–US Data Privacy Framework or standard contractual clauses.

4. Data-subject rights

Access, rectification, erasure, export, restriction, objection and withdrawal of consent are handled as described in the Privacy policy; end-customer requests are routed to the business operating the assistant, which we assist under the Data processing agreement.