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Technical and Organisational Measures

The technical and organisational measures under Article 32 GDPR that reactive.chat actually applies to protect personal data, including where their limits lie.

1. Scope and principle

This document describes the technical and organisational measures ("TOMs") that LW IT Solutions Company Lukas Wójcik, al. Tadeusza Kościuszki 80/82, lok. 301, 90-437 Łódź, Poland, NIP PL7252266190 (the "Operator") applies when operating reactive.chat (the "Service"). It forms Annex B of the Data Processing Agreement ("DPA") and serves the documentation required by Article 32 GDPR. Terms defined in the DPA ("Customer", "Visitor", "Customer Data") have the same meaning here.

Principle. Every measure described here is implemented. Where a measure has a limit, the limit is stated next to it rather than left out, so that the Customer can judge whether the level of protection is appropriate for the data it entrusts to the Service. Risks that remain after these measures are assessed in the Operator's data protection impact assessment; the processing operations themselves are listed in its records of processing activities. Both are not published; the Operator makes them available to the supervisory authority and, on request, to Customers.

Setting. The Service is run by the owner of the Operator personally. It is hosted on one server owned by the Operator (a Raspberry Pi 5) in the Operator's premises in Łódź, Poland. The Service runs in a production installation that is separate from its development installation on the same machine (section 2.4). The same machine also hosts other services of the Operator. The language models run on separate machines of the Operator ("AI nodes") in the same local network. A daily encrypted copy of the server is held off-site with Google Cloud Storage in Warsaw (section 5.1). The organisational measures are sized for a one-person operation: there is no separate security team and no separation of duties between development, operation and review.

The measures are arranged by the categories of Article 32 GDPR: confidentiality (sections 2 and 3), integrity (section 4), availability and resilience (section 5), the ability to restore (section 6), procedures for regular review (section 7), control of processing on behalf (section 8) and measures specific to the AI functions (section 9).

2. Confidentiality – access

2.1 Physical access control

2.2 System access control (authentication)

Customer accounts

API and real-time access

Server administration

2.3 Data access control (authorisation)

2.4 Separation control

3. Confidentiality – minimisation, pseudonymisation and encryption

3.1 Pseudonymisation and data minimisation

3.2 Encryption

3.3 File attachments

3.4 Smart Answer

4. Integrity

4.1 Transfer control

4.2 Input control and logging

5. Availability and resilience

5.1 Backups

There are two backup routes.

Server-wide backup (off-site, encrypted). Every day at about 03:00 an automated job creates a dump of all databases of the server and an archive of the web directories, which include the Service's file attachments, knowledge-base files and company logos.

Database backup of the Service. Every day at 03:05 a second job writes a compressed dump of the Service's database to the server's system disk, readable only by its owner, and keeps it for 30 days. It is not encrypted and does not contain files.

Consequences. Data deleted in the live system remains in backups until they expire: at most 364 days in the weekly off-site copies, at most 30 days in the local database dumps. Selective deletion inside a backup is not performed, because each copy is a sealed image of one point in time. Backups serve only to restore the system after a loss; they are not searched, analysed or disclosed. If a backup has to be restored, the Operator will re-apply the deletions that were carried out after the date of the copy before the Service returns to normal operation (section 6).

5.2 Protection against abuse and overload

5.3 Monitoring

6. Ability to restore

7. Procedures for regular review, assessment and evaluation

7.1 Review of these measures

7.2 Personal data breaches

7.3 Data protection by design and by default

7.4 Organisation

8. Control of processing on behalf (order control)

9. Measures specific to the AI functions

10. Status and version

This document is drawn up in English. Translations into German (/de/p/technische-und-organisatorische-massnahmen) and Polish (/pl/p/srodki-techniczne-i-organizacyjne) are provided for convenience; the English version prevails.

Version 2.0 replaces version 1.4 of 7 October 2026. Changed: the document is rearranged by the categories of Article 32 GDPR and extended by system and data access, encryption, monitoring, recovery, order control and AI measures; the off-site backup at Google Cloud Storage with weekly copies of up to 364 days replaces the statement "backups up to 30 days, no hyperscaler"; statements that did not match operation were removed or corrected (SSH with named keys only, physically separate development and production, mandatory e-mail verification, IP blocks by Customers in the dashboard, deletion of AI job texts after about ten minutes, scrubbing without exceptions, image downscaling before upload); limits are stated (no disk encryption, no malware scan, no separation of duties).

Version 2.1 replaces version 2.0 of 11 October 2026. Changed: minimisation for campaigns, the live visitor list, MCP and evaluations (3.1); limits for custom bot actions (4.1); audit log with single sign-on and MCP calls (4.2); block on job applications and no AI evaluation of Team Members (9).

Version 2.2 replaces version 2.1 of 11 October 2026. Corrected: there is no separate production environment yet, the Service runs in its development installation (1, 2.4, 4.2, 5.3, 6); SSH with password sign-in, fail2ban not effective for SSH (2.2); limits of reCAPTCHA (2.2); scrubbing of telephone numbers and identifiers, system journal with IP addresses (3.1, 4.2); OCR also for recognising job applications (3.3); Smart Answer through Answely with a 24-hour answer cache (3.4); push services on a fixed host list (4.1); audit-log entries without an account are not deleted (4.2); /ban per /64 network for IPv6, fail2ban one hour (5.2); confidential jobs of the AI tools for agents (9).

Version 2.3 replaces version 2.2 of 12 October 2026. Corrected: Smart Answer counter with a shortened IP address, question length and maximum time in transit (3.1, 3.4); chat models of the Operator's own AI with a reserve model (9); block on job applications on all model paths except translation (9); periods of 16 October 2026: expired sessions and tokens deleted (2.2), audit-log entries without a workspace deleted after 90 days (4.2). Supplemented on 16 October 2026: country for the live functions derived from the IP address (3.1); file names written as text (9). Further supplemented on 16 October 2026: second factor mandatory for the operator administration area (2.2); encrypted secret of two-factor authentication (2.2, 3.2); deletion journal for re-applying deletions after a restore (6); file names recognised regardless of spaces and other separators, spelling and accents (9).

Version 2.4 replaces version 2.3 of 16 October 2026. Changed: session identifiers stored in the database only as SHA-256 hashes (2.2, 3.2).

Version 2.5 replaces version 2.4 of 17 October 2026. Changed: the AI is described uniformly as the Operator's own, self-hosted AI; model and software names removed, the facts are unchanged (9).

Version 2.6 replaces version 2.5 of 17 October 2026. Corrected: a transfer to the production instance does not save the state it replaces and does not restore it automatically; how such a transfer is ordered and carried out, and that it is currently blocked (6).

Version 2.7 replaces version 2.6 of 18 October 2026. Changed: the separate production installation with its own database user, Redis database and AI worker instances (1, 2.4); transfers to the production installation only of committed versions, by hand, with a backup beforehand and restoration of the program files (4.2, 6); the records of processing activities and the data protection impact assessment are available on request instead of published (1).

Version 2.7 – effective 19 October 2026.

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