Data Act: switching, export and portability

1. Purpose of this page

Regulation (EU) 2023/2854 (the "Data Act") applies since 12 September 2025. Chapter VI (Articles 23 to 31) gives customers of data processing services the right to switch to another provider or to their own infrastructure, and obliges providers to make that switch possible, documented and free of obstacles.

reactive.chat is a data processing service within the meaning of Article 2(8) of the Data Act: a live-chat service offered as software as a service. This page, together with the Terms of Service, is the information that Articles 25 and 26 require the provider to give before the contract is concluded. Both are available before registration. Where this page and the Terms differ, the Terms prevail; where the Terms are silent, the mandatory rules of Chapter VI apply directly.

Terms used on this page:

• Operator ("we"): LW IT Solutions Company Lukas Wójcik, al. Tadeusza Kościuszki 80/82, lok. 301, 90-437 Łódź, Poland, VAT ID PL7252266190, contact@lukaswojcik.com – the provider of the data processing service.
• Customer: the business that holds an account and embeds the widget on its website.
• Visitor: a natural person who uses the chat widget on the Customer's website.
• Service: reactive.chat, including the widget, the dashboard, the knowledge base, the AI assistant and the optional channels and integrations.

2. Which parts of the Data Act apply

• Chapter VI (switching, Articles 23 to 31) applies; this page describes how we meet it.
• Article 32 (international governmental access) applies; see section 11.
• Chapters II and III (data from connected products and related services) do not apply: reactive.chat is a web application, not a connected product or a service related to one.
• Chapter IV (unfair terms in data-sharing contracts) concerns contracts on access to and use of data between businesses; our Terms contain no term that prevents the Customer from obtaining or using its own data.
• Personal data first. The Data Act does not override the GDPR. Conversations and Visitor records are personal data that the Customer controls and we process on its behalf under the Data Processing Agreement. Everything on this page about export and switching applies within those limits (section 10).

3. Your right to switch

The Customer may, at any time and for any reason:

• switch to another data processing service of the same type (another live-chat provider);
• port its exportable data to its own infrastructure;
• end the contract and have its data erased.

We put no commercial, technical, contractual or organisational obstacle in the way. There is no minimum term beyond the paid billing period, no proprietary data format and no charge for leaving.

4. Export does not need notice

Exports are self-service. The Customer can download its data at any time during the contract, as often as it likes, without telling us and without ending anything (section 7). A switch therefore never depends on our cooperation for the data the dashboard exports; for the few categories that are only available on request, we deliver within 30 days.

5. Notice period and end of the contract

• Ordinary termination. A paid subscription is cancelled in the dashboard under Billing, or by e-mail to contact@lukaswojcik.com. It ends at the end of the current billing period: monthly plans at the end of the month, annual plans at the end of the year. Until then the cancellation can be withdrawn.
• Switching notice. Under Article 25(2)(d) the notice period for initiating a switch may not exceed two months. If the Customer asks for it when cancelling, in particular in order to switch, the cancellation takes effect at the latest two months after we receive it, also on an annual plan. Fees paid in advance for the time after that date are refunded pro rata. We charge no switching or early termination fee.
• Free plan. The free plan can be ended at any time by deleting the workspace or the account.

A switching request is made by e-mail to contact@lukaswojcik.com from the address of the workspace's owner. It should say whether the Customer wants an export, an erasure, or both, and to which date.

6. Transitional period

After the notice period a transitional period of at most 30 calendar days begins (Article 25(2)(a)), during which the Customer completes the move. The Service remains available under the existing contract, all exports remain possible, and we answer reasonable questions about the exported data.

If 30 days are technically unfeasible in a specific case, we tell the Customer within 14 working days of the switching request, explain why, and name an alternative period of at most seven months (Article 25(4)). We expect this to be exceptional: the formats below are standard, and the export is self-service. The Customer may ask once for a longer transitional period if it needs more time on its own side.

7. Exportable data and formats

7.1 In the dashboard, without asking us

Under Workspace → Export owners and admins download, per project, either JSON (one file) or a ZIP archive of CSV files. The export contains:

• conversations and messages, with time stamps, assignment, status, tags, ratings and comments, form answers and translations;
• Visitor records with the traits the Customer supplied (name, e-mail, user id, own fields), sessions and events;
• the AI log (answers with sources), the read log, quality reviews and service-level escalations;
• callbacks and call logs, channel identities and e-mail threads, campaigns and their contacts;
• canned responses, help articles, bot and flow versions, simulations;
• the knowledge base: document details, the crawled page text, corrections, crawl runs, product data and data-layer settings;
• the project settings (including the assistant's name, role text and configuration, proactive messages, tours, privacy settings), report tiles, webhook definitions, single sign-on settings, workspace protection and rights settings;
• the list of roles in the workspace (identifiers and roles);
• attachments: in the ZIP archive the files themselves, up to 2 GiB per export (missing files are named, and we deliver them on request); in JSON a list with name, type, size, upload time and checksum.

Further exports in the dashboard: the audit log (CSV), the AI log (CSV and JSON), reports (CSV), A/B test results (CSV), the read log (Agency plan), invoices (PDF), and for each team member a personal export of their own account data (JSON).

Where the plan includes API keys, conversations, messages and Visitor data can also be read through the REST interface (API v1).

7.2 On request

Not in the dashboard export, but delivered on request by e-mail to contact@lukaswojcik.com within 30 days, normally sooner:

• the original files uploaded to the knowledge base;
• names and e-mail addresses of the team members;
• the workspace's master data (name, plan, billing details).

7.3 Not exported

• Credentials: API keys, access data of channels and integrations, access data of an import from another provider, invitation and transfer links. They are access data, not Customer data; an export is a file that leaves our control, and they never go into it.
• Internal working data that can be rebuilt from the exported data: the search index of the knowledge base (text segments and their vectors), the queue of AI requests, counters, import mappings.
• Our own software and know-how: widget, dashboard and server code, the configuration of our AI nodes and the model weights.
• Security data derived for the protection of all tenants: block lists, rate-limit counters, spam scores, the server's security log; and server access logs, which are deleted after at most 15 days anyway.
• Data of other Customers.

Content of third-party channels and integrations (e-mail, Slack, WhatsApp, Telegram, Messenger, Instagram, CRM and helpdesk tools) remains with the respective provider, with whom the Customer has its own contract. Messages that reached the Service through such a channel are part of the exported conversations.

7.4 Format documentation

JSON and CSV are open formats that need no particular tool. Field names correspond to the names of the underlying tables and columns. On request we describe the structure (fields, types, relationships) in writing during the transitional period. A change of the format is announced on this page.

8. Switching charges

We charge nothing for switching, for exports or for the assistance described here – neither now nor after 12 January 2027, from which date Article 29 forbids switching charges altogether. There are no data egress fees. Subscription fees remain payable only for the paid period, as set out in the Terms.

9. Retention after switching and after the end of the contract

The end of a contract or a subscription does not delete anything. When a paid subscription ends, the workspace returns to the free plan and the data stays available; the Customer can keep exporting it for as long as the workspace exists. This exceeds the minimum retrieval period of 30 days required by Article 25(2)(g).

Erasure on request. The Customer has its data erased by deleting the workspace or its account in the dashboard, or by asking us (Article 25(2)(h)). A deletion starts a grace period of 30 days in which it can be cancelled; then the data is erased from the live system. While a paid subscription is running, the deletion of a workspace or account is refused; cancel the subscription first. Details, including what remains after a deletion, are in Access and deletion.

Backups. Erased data remains in backups for at most 364 days: the encrypted daily system backup keeps daily copies for 7 days and one weekly copy for 364 days; a local copy of the same backup is kept on a disk attached to our server for about 8 days; the database backup on our server is kept for 30 days. We do not delete selectively from backups. If a backup has to be restored, we will apply again, before the Service returns to operation, the deletions carried out since the backup was made; they are recorded for this purpose in a deletion journal (see Access and deletion, section 4). A deletion requested after the backup was made that was still in its 30-day waiting period is not recorded and has to be requested again.

Invoices are kept at least for the period Polish tax law requires; they contain billing data, never Visitor data.

We recommend exporting before deleting: erased data cannot be recovered.

10. Data about Visitors

The exported conversations and traits contain personal data of Visitors. The Customer is the controller; we hand the data only to the Customer, never directly to a new provider. When moving it, the Customer should keep in mind:

• the new provider becomes the Customer's processor and needs its own agreement under Article 28 GDPR;
• the Customer remains responsible for the lawfulness of the transfer, for informing Visitors and for answering their requests;
• the switch is a good moment to export only what is still needed and to apply the Customer's own retention rules;
• Visitor requests that reach us after the switch are forwarded to the Customer as long as we still hold data; afterwards we can only confirm that we hold none.

11. Location of the infrastructure and governmental access

• Location (Articles 26 and 28). The Service runs on a server owned and operated by the Operator in our premises in Łódź, Poland. The AI models run on our own computers in the same local network. The content delivery host cdn.reactive.chat is a web host on the same server, not an external network.
• Backups. The daily system backup is encrypted on our server, with keys that stay on our server, and stored with Google Cloud Storage in the region europe-central2 (Warsaw, Poland). The provider belongs to a group based in the USA and may also be subject to US law; it receives only the encrypted backup and not the keys. A local copy of the backup is kept on a disk attached to our server in Łódź for about 8 days.
• Applicable law. Our infrastructure is subject to Polish law and the law of the European Union.
• Requests from third-country authorities (Article 32). We disclose Customer data to an authority of a third country only where the request is based on an international agreement or meets the conditions of Article 32(3). We examine every request, challenge it where the law allows, disclose only the minimum necessary and, where we are permitted to, inform the Customer before disclosure.

The technical and organisational measures that protect the data are described in Technical and organisational measures; the list of sub-processors is at Sub-processors.

12. Functional equivalence and interoperability

Functional equivalence after a switch (Article 30(1)) is an obligation for infrastructure services. reactive.chat is a software service; for it Article 30(2) requires open interfaces and the export of exportable data in a structured, commonly used and machine-readable format. We meet this with the exports in section 7 and the REST interface (API v1). We do not re-implement the Service at a new provider and do not guarantee that another product offers the same features; the Customer or the new provider maps the exported data to the new system. We will follow the harmonised standards for data processing services once they are published.

Switching to us works the other way round: the dashboard imports conversations from the export files of Intercom, Crisp, Tidio and Zendesk.

13. Questions and complaints

Questions about switching or export, and switching requests: contact@lukaswojcik.com. Complaints are handled as described on Complaints and answered within 14 days.

This document is drawn up in English. Translations into German (/de/p/data-act) and Polish (/pl/p/data-act) are provided for convenience; the English version prevails.

Version 2.2 replaces version 2.1 of 12 October 2026. Corrected: a deletion is refused while a paid subscription is running (9). Supplemented on 16 October 2026: re-applying deletions after a restore through the deletion journal (9).

Version 2.2 – effective 16 October 2026.