Privacy Policy

1. About this policy

This policy explains how Aleksify (“Aleksify”, “we”, “us”) handles personal data in connection with Chat Buddy (the “Service”).

We are established in Serbia.

2. Our two roles

Chat Buddy serves businesses (“customers”) who embed an assistant on their own websites, where it talks to their visitors. That means we handle personal data in two different capacities, and it matters which one applies:

• As controller - for our customers’ own account data: the person who signs up, their business, their billing relationship with us, and their use of the dashboard.
• As processor - for everything a customer’s assistant handles on their behalf: their catalog and knowledge base, and the conversations their website visitors have with the assistant. Here our customer is the controller, we act on their instructions, and their own privacy policy governs how they treat their visitors’ data.

If you are a visitor to a website using Chat Buddy and you want your data removed, the fastest route is to contact the business whose website you used. You can also contact us at contact@chat-buddy.app and we will pass the request to them.

3. What we collect

Customer account data (we are controller): name, business name, email address, password hash or Google sign-in identifier, session and login records, support correspondence, and billing records (see section 5 - card details are handled by Paddle, never by us).

Customer content (we are processor): the product catalog, knowledge-base documents, assistant configuration, branding and website domains a customer uploads or configures.

End-visitor data (we are processor): data created when someone chats with a customer’s assistant. Specifically: the messages exchanged; details a visitor submits through the assistant, such as a name, email address, phone number, delivery address or appointment request; orders placed; a record of when a visitor asked to speak to a person and the reason given; the visitor’s IP address and the approximate city and country derived from it; the visitor’s browser time zone; and the text of questions the assistant could not answer, which we keep so the customer can improve their knowledge base. A customer may also block a specific IP address, which we store for that purpose.

Data that must not be submitted. The Service is not designed for sensitive data. Customers must not upload, and must not configure their assistant to ask visitors for:

• government identification numbers, such as passport or national ID numbers;
• payment card numbers or bank account credentials;
• passwords or other access credentials;
• health or medical records;
• biometric or genetic data;
• any other special category of personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, sex life or sexual orientation), or data about criminal convictions and offences.

We do not knowingly collect such data. If we find it in the Service, we may delete, block or anonymise it.

4. Why we process it, and on what basis

• To provide the Service - performance of our contract with the customer. For end-visitor data we act on the customer’s instructions under section 2.
• To take payment - performance of a contract, and compliance with tax and accounting obligations.
• To keep the Service secure and prevent abuse - our legitimate interest in protecting the Service, our customers and their visitors. This is why we process IP addresses and rate-limit requests.
• To support customers and send service messages - performance of a contract and our legitimate interest in operating the Service.

5. Sub-processors

We use the following providers to run the Service. Which AI providers apply to a given customer depends on the plan and configuration they choose.

Chat content is sent to the selected AI provider in order to generate a reply, and catalog and knowledge-base text is sent to the embeddings provider so the assistant can search it.

AI providers receive this content through their APIs solely to generate responses for the Service. We do not use chat content, catalog or knowledge-base data to train AI models, and we use our AI providers only on paid API terms under which they may not use it to train or improve their models. Under those terms they may keep it for a limited period for abuse and misuse monitoring before deleting it.

We will update this list at least 14 days before adding or replacing a sub-processor. Customers may object to a change on reasonable data-protection grounds by contacting us.

6. Where data is stored, and international transfers

We are established in Serbia. The database and cache that hold customer content and conversations are hosted in the European Union, in Railway’s Amsterdam (Netherlands) region.

Personal data can nevertheless cross borders in two ways, and each has its own safeguard:

• From customers in the European Economic Area to us. Serbia is not covered by an EU adequacy decision. Where we process personal data as a processor for a customer in the EEA, we do so under a data processing agreement that incorporates the European Commission’s Standard Contractual Clauses (Module 2, controller to processor).
• From us to our sub-processors. The table below shows where each sub-processor handles data and the safeguard we rely on. For data originating in the EEA we use the European Commission’s Standard Contractual Clauses (Module 3, processor to processor, or Module 2 where we are controller). For data we export from Serbia we use the standard contractual clauses adopted by Serbia’s Commissioner for Information of Public Importance and Personal Data Protection, except where Serbian law recognises the destination as providing an adequate level of protection.

You can ask us for a copy of the relevant safeguards using the contact details in section 8.

7. How long we keep data

Customer account and billing records are kept for as long as the account is active and afterwards for as long as we must keep them for legal, tax and accounting purposes.

Customer content and conversation data are retained while the customer’s account is active, until the customer deletes them. A customer can delete a conversation and the personal data associated with it from their dashboard at any time; doing so removes the messages, any details submitted through the assistant, related orders and requests, and any block placed on the visitor’s IP address.

When an account ends, its customer content and conversation data are deleted within 30 days, except for records we must keep by law. Copies in our backups are deleted as those backups expire, within 30 days.

8. Your rights

Subject to applicable law, you have the right to access the personal data we hold about you, to have it corrected or erased, to object to or restrict how we process it, and to receive it in a portable format. You also have the right to complain to your local data protection authority.

To exercise any of these rights, contact contact@chat-buddy.app. If your request concerns a conversation you had with an assistant on someone else’s website, see section 2 - that business is the controller, and we will forward your request to them.

We respond within one month of receiving a request. Where a request is complex or one of many, we may extend this by up to two further months, and we will tell you if we do. Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive.

9. Security

Customer data is separated by tenant at the application layer and enforced again in the database, so one customer’s data is not reachable from another’s account. API keys supplied by customers are encrypted at rest. Access to production systems is limited to those who need it, and administrative actions on customer data are recorded in an audit log.

No system is perfectly secure. If we become aware of a breach affecting your personal data, we will notify you and the relevant authority as required by law.

10. Cookies

Our public website sets no tracking or advertising cookies. The customer dashboard uses a single cookie to keep you signed in, which is strictly necessary for it to work. The embedded assistant stores a short-lived identifier in the visitor’s browser so a conversation survives a page reload.

11. Children

The Service is intended for businesses and is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us and we will delete it.

12. Changes to this policy

We may update this policy. When we do, we will update the “last updated” date above, and we will tell customers about material changes by email or in the dashboard.