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Privacy Policy

How LW IT Solutions Company Lukas Wójcik processes personal data on the reactive.chat website, in customer accounts and in the chat widget on customers' websites – with purposes, legal bases, recipients, backups and retention periods.

This privacy policy explains how LW IT Solutions Company Lukas Wójcik ("we", "us", the "operator") processes personal data in connection with reactive.chat. It has three parts, because we act in different roles:

Sections 5 to 12 apply to all three parts. Where this policy states a period, it is the period our systems actually enforce; where no system deletes something after a period, we say so.

Two further documents describe the same processing from the controller's side: our records of processing activities (Art. 30 GDPR) and our data protection impact assessment (Art. 35 GDPR). They are not published; we make them available to the supervisory authority and, on request, to Customers (contact@lukaswojcik.com).

1. Controller and contact

For all questions about data protection, write to contact@lukaswojcik.com. Requests are handled by the owner personally. We have not designated a data protection officer.

1.1 Where the service runs

reactive.chat runs on a server owned and operated by us in our premises in Łódź, Poland. Our own AI runs self-hosted on separate machines of our own (our "inference nodes"), which stand in the same local network as that server. The address cdn.reactive.chat, from which the widget is loaded, is not an external content delivery network but a website on the same server. The server is connected to the internet by a network operator (Toya Sp. z o.o., Łódź), which transports encrypted data and has no access to its content.

The service runs in a production installation (reactive.chat) that is separate from its development installation (dev.reactive.chat): it has its own program directory, its own database with its own database user, its own Redis database and its own service processes. Changes to the code reach the production installation only through a deliberate transfer of a fixed version, after a backup of its program files and database. Both installations run on the same server and use the same AI nodes; the development installation is protected by a password. The same server also carries other projects of the operator; they are separated by directories, databases and database indexes on that machine, not by separate hardware.

Copies of the data leave this server in exactly one regular case: the encrypted backup described in section 7.1. All other recipients are listed in section 5.

2. Part A – Visitors of the reactive.chat website

2.1 Server access log and operating logs

When you open a page on reactive.chat, our web server records the request: date and time, the requested address, the HTTP status, the referring page, the browser type and version (user agent) and your full IP address. The same applies to requests to cdn.reactive.chat and to the real-time connection of the chat. We use the access log to operate the site securely, to detect attacks and errors and to keep the service stable. An automated blocking tool reads the logs and blocks addresses that attack the server for one to two hours.

2.2 Theme choice (localStorage)

If you switch between the light and dark theme, your choice is stored in your browser under the key rc_theme in localStorage. It is used only to display the site in the theme you chose and not for tracking. Storing this value is strictly necessary to provide a function you have explicitly requested (Art. 5(3) ePrivacy Directive, Polish Electronic Communications Law), so no consent is required. You can delete it at any time in your browser settings.

If you close a notice bar on the site, the key rc_leiste_zu: followed by the name of that notice is stored with the value 1 in localStorage, so that the notice is not shown again. It contains no identifier, has no expiry and is strictly necessary for the function you used; no consent is required. You can delete it at any time in your browser settings.

2.3 Language choice

The language of the site is part of the address (URL path). Nothing is stored in your browser for this purpose.

2.4 Support form

If you send us a message through the support form, we process the details you enter (such as your name, e-mail address and the text of your message), the page and language you wrote from and your full IP address, to answer your request.

2.5 E-mail contact

If you e-mail us at contact@lukaswojcik.com, we process your e-mail address and the content of your message to answer you. That mailbox is hosted by Namecheap (section 5). Legal basis as in 2.4. We keep e-mails as long as they are needed to handle your request and any follow-up questions and to document what was agreed; there is no automatic deletion.

2.6 No tracking

Apart from the items listed in this Part, the reactive.chat website stores nothing in your browser and loads no scripts, fonts or images from other providers. We do not use web analytics, advertising or tracking pixels. Links to other websites (for example consented.eu or mouseplayer.com) are ordinary links; nothing is transmitted to those websites until you follow them.

2.7 reCAPTCHA

On the login, registration, password-reset and support forms we use Google reCAPTCHA v3 to distinguish people from automated scripts. reCAPTCHA is never used inside the chat widget.

2.8 Security cookie (rc_csrf)

When you open a page of the reactive.chat website, our server sets a cookie named rc_csrf in your browser if it is not there yet. This happens on every page, also if you are not signed in and do not fill in a form, because the support dialog can be opened from every page and a form only works if the cookie already exists when the page is loaded. The cookie contains a random value of 64 hexadecimal characters that our server generates and that contains no information about you. From this value – and, once you are signed in, from your session – the server calculates a token that is placed in each form of the website and the dashboard (for example sign-in, registration, password reset and support) and checked when you submit it. Another website cannot calculate this token and therefore cannot submit a form in your name (protection against cross-site request forgery, CSRF).

3. Part B – Customers and team members

reactive.chat is offered to businesses only. This Part applies to the person who registers a Customer account and to every team member (roles owner, admin, member – the agent role – and viewer) who is invited into a workspace. We are the controller for the account data described here. For the content you process with reactive.chat (conversations, knowledge base, data of visitors and of your end customers) you are the controller and we are your processor – see Part C and the data processing agreement.

3.1 Registration and account

3.2 Team members

The owner or an admin of a workspace invites team members by e-mail. We process the invited person's e-mail address and role to send the invitation (valid for 7 days) and, after acceptance, to operate the account. A workspace can also be offered for transfer to another member (offer valid for 7 days). Team members can ask the workspace owner or us to correct or delete their data – see Access and deletion.

3.3 Billing

Paid plans are billed through Stripe (section 5). When you start a paid plan we transmit to Stripe your e-mail address, your name or company name, your address where it is complete, and internal identifiers of your account and workspace as reference; in the checkout Stripe collects the billing address, an optional VAT number and the payment method itself. Card data is processed only by Stripe; we never receive card numbers.

3.4 E-mail

We send e-mails about registration, e-mail confirmation, password reset, invitations and notifications (for example about unanswered conversations) through our e-mail service. The same service is used for e-mails to visitors that a Customer's chat triggers – a copy of the conversation that a visitor requests, and replies in the e-mail channel where the Customer has not entered a mail server of its own (4.6). The provider currently used is named in the sub-processors list; see section 5. If e-mail sending is not available, outgoing messages are kept as files on our server and deleted after 30 days. Legal basis: Art. 6(1)(b) GDPR; for visitor e-mails, the Customer's instruction (Part C).

3.5 Support, feedback and status

Support requests from Customers are handled as described in 2.4 and 2.5. The feedback button in the dashboard stores your text, the page and the user agent with your account; we receive a notification via Telegram without its content (5.3). The public status page shows only measurements of our own systems.

3.6 Channels and integrations you connect

You may connect channels (e-mail via your own IMAP/SMTP server, WhatsApp, Facebook Messenger, Instagram, Telegram, SMS) and integrations (for example Slack, Microsoft Teams, Discord, HubSpot, Pipedrive, Zendesk, Freshdesk, Jira, Linear, GitHub, Shopify, Shopware, WooCommerce, WordPress, Stripe, Google Analytics 4, Plausible, Matomo, Sentry, Notion, Confluence, Google Drive, Cal.com, Zapier, Make, n8n, webhooks) and import data from Intercom, Crisp, Tidio, Zendesk or Answely. You use your own accounts and credentials for this; we store the credentials encrypted and use them only to operate the connection on your instruction. The providers of these services are your own recipients or processors, not our sub-processors. You are responsible for the lawfulness of the data exchange with them. The Google Drive connection uses an OAuth application registered by us; Google therefore sees that you authorise that application, while the documents are read from your Drive on your instruction. What reaches those providers is described in 4.6.

3.7 Retention of account data, end of contract and deletion

3.8 Read log (Agency plan)

In workspaces on the Agency plan – with an active subscription, including a trial period, or under an individual contract – the Service records which team member opened which conversation and when. The owner and the admins of the workspace see this read log for the projects they have access to; members and viewers do not.

3.9 Sign-in, sessions, two-factor authentication and SSO

3.10 Web push notifications

Team members can allow their browser to show notifications about new conversations, new messages, handovers and call-back requests. If you do, we store the subscription your browser gives us (an address at the push service of your browser's maker and two keys), at most 10 per account. A notification contains only the kind of event, the name of the project, the identifiers of the project and conversation with a link to open it, and the time – not the text of messages. Its content is encrypted end-to-end so that only your browser can read it; the push service (Google, Mozilla, Apple or Microsoft, depending on the browser) nevertheless learns the subscription address, the time and the size of each message and our server's IP address (section 5). A subscription is deleted when you switch notifications off, when it has not been seen for 60 days, when it no longer belongs to a valid session, or after ten failed deliveries. Legal basis: Art. 6(1)(b) GDPR, at your request.

3.11 Audit log, AutoQA and other evaluations of team work

4. Part C – Visitors of Customers' websites (chat widget and related functions)

4.1 Roles

The Customer embeds the reactive.chat widget on its website and decides whether, how and for what purpose it is used. The Customer is therefore the controller for your data (Art. 4(7) GDPR). We process the data on the Customer's behalf as processor under a data processing agreement pursuant to Art. 28 GDPR. Information about the specific purposes and legal bases must be provided by the Customer in its own privacy policy. Please address requests concerning your data to the Customer. If you contact us directly, we forward your request to the Customer and assist – see Access and deletion.

The same applies to Smart Answer (4.14), to messaging channels (4.6), to calls and call-back requests (4.17), to campaigns (4.16) and to the customer portal (4.18).

4.2 Data processed in the widget

The widget script is loaded from cdn.reactive.chat. When it loads and while you chat, the following data is processed:

4.3 Storage in your browser

The widget sets no cookies – neither its own nor third-party cookies – and contains no advertising or tracking pixels. It uses the web storage of your browser for the website on which it is embedded. Which storage it uses depends on the consent signal of the Customer's consent management platform (an IAB TCF signal for storage on the device, the consented.eu signal, or a value the Customer passes):

Keys used:

The legal basis for browser storage is Art. 5(3) ePrivacy Directive as implemented by the Polish Electronic Communications Law and the law of the Customer's country: sessionStorage is strictly necessary to run the chat you requested; persistent storage requires your consent, which the Customer obtains. The rc_dnt bit stores your own deletion decision and is strictly necessary to respect it.

4.4 AI assistant

The Customer may enable an AI assistant (default name "Ada") that answers your questions.

Several functions deliberately use no language model: recognising abuse and requests for deletion (4.11), the fixed answer to questions about what is stored, the frustration signals (4.19), the set-up suggestions in the dashboard and the rule-based part of AutoQA.

4.5 Human agents

The Customer's agents read and answer conversations in a web dashboard. Access is role-based (owner, admin, member, viewer) and limited to the Customer's own workspace and, where the Customer restricts it, to individual projects. Agents can assign, tag and close conversations, use prepared answers, send quick replies, cards, forms and attachments, ask for a CSAT rating, leave internal notes, transfer conversations, and see a live list of the visitors currently on the website and invite them to chat. Conversations can be routed and assigned automatically by rules and service targets. Proactive messages and product tours are configured by the Customer.

Live visitor list: it is built only from data your session already carries; nothing is collected for it. Without consent it shows only a random identifier, times, whether a conversation is running and that consent is missing. The full line – page without parameters, referring host, campaign parameters, device, browser and operating-system family, country (derived from your IP address, 4.2), language, whether you have visited before – is shown only where the Customer's project does not require consent or you have consented; for visitors from the GDPR area and wherever the country is unknown, only with your consent (4.10). The list never shows your IP address, the raw browser identification, advertising click identifiers or your name and e-mail address. It exists only in our memory store, renewed every 90 seconds at most – in practice every 30 seconds – and expires 90 seconds after the last renewal; you disappear from it 45 seconds after leaving the website and after 30 minutes without activity. An agent can invite you to chat from the list (at most once every 2 minutes per visitor), under the same consent rule. The Customer's systems can read the same list through our API (4.6).

An agent can block a visitor for up to 365 days (24 hours unless set otherwise). The block applies to the visitor id on that website and to the IP address of the connection; where the visitor connects directly to our server, a blocked IP address is blocked for the whole service, not only for that Customer's website. Agents can also use a language model to translate messages and to prepare reply drafts and summaries (4.15).

4.6 Channels, integrations and session replay activated by the Customer

The Customer may connect further channels and integrations. If it does, conversation data is exchanged with those providers on the Customer's instruction. Those providers are recipients or processors of the Customer, not our sub-processors.

4.7 PII scrubbing

Before a message from a visitor or an agent is stored, our server automatically replaces patterns that look like e-mail addresses, card numbers (checked with the Luhn algorithm), IBANs (checked with the ISO check digits), telephone numbers, tax identifiers and secrets such as access keys with a placeholder; the redactions are counted and marked in the message. Two exceptions: messages that a Customer's system writes through our API, and answers to forms in the chat, are stored as sent. This is a protective filter, not a guarantee; please do not enter payment data in a chat.

4.8 Content filters

We are not a party to the conversation and do not review messages editorially. We apply only automated filters: PII scrubbing, spam detection and abuse detection (including the detection of attempts to misuse the AI assistant for unrelated tasks), all by fixed rules. Illegal content can be reported to contact@lukaswojcik.com; see also Acceptable use and anti-abuse.

4.9 Abuse protection

The real-time server protects itself and the Customers against hammering, flooding and spam. It counts requests per connection and per IP address and limits the size and number of messages and the use of the AI assistant per website and per address. When limits are exceeded, it can block a connection, a visitor id or an IP address automatically and temporarily (24 hours unless set otherwise); blocks are kept in our server's memory store for their duration. Manual blocks are kept by us and by Customers (4.5). The latest 500 security events of this guard, with IP address, are kept in a rolling list without a time limit; older events are overwritten. Each connection can address only conversations of its own site (tenant isolation by site key). Within the Customer's processing this is a security measure under Art. 32 GDPR; as far as we protect our own service, our legal basis is Art. 6(1)(f) GDPR.

For the "Powered by reactive.chat" notice on the free plan we count displays and clicks; the IP address is used only as a shortened, one-way hashed value for ten minutes to avoid double counting, and the counters are kept for 40 days.

4.10 Legal bases

The Customer determines the legal bases. Typically these are Art. 6(1)(b) GDPR (answering a request you make before or during a contract), Art. 6(1)(f) GDPR (the Customer's legitimate interest in offering a chat and in protecting it against abuse) and your consent for persistent browser storage. The Customer can also set the chat to ask you for your consent before you can write; where the Customer does that, the legal basis for processing your messages is your consent (Art. 6(1)(a) GDPR), the chat shows you the wording you agree to, and no conversation is created and no page text is sent until you have agreed. That consent is a different one from the consent for persistent browser storage in 4.3, which covers only the storage on your device. The Customer's own privacy policy is decisive.

For visitors from the GDPR area – the member states of the EU, the EEA states Iceland, Liechtenstein and Norway, the United Kingdom and Switzerland – and whenever the country cannot be determined, three functions run only with your consent, whatever consent level the Customer has chosen: campaigns in the widget (4.16), the full line about you in the live visitor list, and invitations to chat from that list (4.5). The country is derived from your IP address with the country database described in 4.2 (country code only); country information sent by your browser is not used. Where no country can be derived – for example for private or unknown addresses –, consent is required.

4.11 Retention

No automatic period unless the Customer sets one. Conversations are kept until they are deleted. Our service does not delete them after a fixed period by default: the Customer, as controller, sets per project after how many days of inactivity conversations are deleted (from 0 = no limit up to 3,650 days). That figure can be capped by an upper limit we set and by a limit agreed in an individual contract; the lowest of the figures applies. A daily run removes conversations that have been inactive for longer. Where no figure is set anywhere – which is the default – no period applies and the conversation remains for as long as the Customer's project exists. The end of a paid subscription does not delete anything (3.7).

The following end a conversation:

There is currently no function in the dashboard with which agents delete individual conversations. If you ask the Customer to delete your conversation, the Customer can use the means above or ask us for help.

The Customer chooses what deletion means: either the conversation is erased, or it is anonymised – the message texts are replaced by a placeholder, translations and form answers are removed, the conversation loses its visitor id and the CSAT comment, the session loses the user agent, the country and the attribution data, and the records of the AI processing of the conversation are emptied. The random session and visitor identifiers themselves remain, so that visitor counts do not change retroactively; after this they stand next to nothing that describes a person, and the conversation remains only as an anonymous entry (time, channel, status, rating) in the Customer's statistics. A question the Customer has adopted into its knowledge base stays there as the Customer's content. Attachments are deleted in both cases (4.12).

A deletion of your chat data also removes the counters kept about you for campaigns (4.16) and, for a WhatsApp conversation, the campaign contact with its deliveries, except a blocking note after an opt-out (4.16). On anonymisation, AutoQA ratings lose the AI's reason and the agent reference (3.11).

Our real-time server also keeps a working copy of each active conversation in its memory store: the latest messages (at most 200), the conversation header with any name, e-mail address or telephone number you have given, and the pages visited; it expires 30 days after the last activity and is cleared together with the conversation. The page context of a session expires after 30 minutes without activity.

The consent record described in 4.2 has no automatic deletion period. When you delete your chat data (in the window or in words), or when the conversations it belongs to are deleted under the Customer's retention period, it is not erased but depersonalised: the session, visitor and conversation identifiers, the IP address and the user agent are cleared and the row is marked as deleted. What is left carries no reference to you and documents only that consent to a particular wording was given, and withdrawn, on a particular day – the accountability that Art. 5(2) GDPR requires of a controller. When a Customer's project or workspace is deleted, these records are deleted with it.

Copies in backups are kept for up to 364 days (7.1).

4.12 File attachments

In the chat you can attach files: images (PNG, JPEG, WebP, HEIC/HEIF, SVG), PDF documents, and text and CSV files. We process the file itself, its file name, type and size, the time of upload and a checksum (SHA-256); for PDF, text and CSV files also a text extract taken from them.

4.13 Order and invoice data from the Customer's shop

If the Customer has enabled this feature on a paid plan, the AI assistant (4.4) can answer questions about your own orders – for example about order, shipping or payment status.

4.14 Smart Answer (AI answers in website search)

The Customer may add Smart Answer to the search on its website. If your search input is phrased as a question, a brief answer written by a language model, with links to its sources, then also appears above or below the results. Smart Answer is a separate service of the operator (the Answely service) on the same server; the roles are the same as for the chat widget: the Customer is the controller, and we process your data on the Customer's behalf (4.1).

What happens to question and answer is set by the Customer per project ("Store search queries"):

In both cases:

4.15 AI tools for agents: translation, reply drafts, summaries

In the dashboard, the Customer's agents can use a language model to help them with a conversation. These tools are available whether or not the Customer uses the AI assistant (4.4). Reply drafts, summaries, rewording and the translation of replies can be used only by team members who may answer conversations.

4.16 Campaigns

On paid plans the Customer can run campaigns: targeted messages in the widget and, through WhatsApp, messages to contacts who have agreed to receive them.

4.17 Call-back requests, voice and video calls, co-browsing

If the Customer and we have switched them on, the widget offers call-back requests, voice and video calls and co-browsing.

4.18 Customer portal

The Customer can give its end customers access to their cases in a customer portal. If you use it, we process the case, your contributions to it and a pseudonymous key of yours; your portal session is valid for one hour. Cases have no separate period and are deleted with the project.

4.19 Error reports, frustration signals and A/B tests

4.20 Test runs and versions of the assistant

The Customer can test its assistant with test questions before going live. It can write them itself or adopt questions that visitors actually asked and the assistant could not answer (knowledge gaps); before such a question is adopted, it passes through the PII scrubber (4.7), and if the scrubber is unavailable, nothing is adopted. Adopted questions (at most 500 characters) and the answers of the test runs are the Customer's content: they are not linked to you, are not removed by a deletion request and are deleted with the project. Test runs create no conversation. Each saved change of the assistant's settings is kept as a version with the person who saved it, without a time limit; of the guided flows, the latest 100 versions per project are kept.

5. Recipients and sub-processors

We use the following sub-processors and recipients. The current list with addresses and safeguards is published at Sub-processors.

5.1 Sub-processors

  1. Google Cloud EMEA Limited, Dublin, Ireland (Google Cloud Storage) – storage of the encrypted daily backup of the whole server (7.1) in a storage location in Warsaw, Poland (region europe-central2). The backup is encrypted on our server before it is transferred, including file and directory names; the keys stay on our server, and Google cannot read the content. Affects all data described in this policy.
  2. Stripe Payments Europe, Ltd., Dublin, Ireland – payment processing and invoicing for Customers (3.3). Stripe never receives visitor data from our billing.
  3. Google Ireland Limited, Dublin, Ireland – reCAPTCHA on the login, registration, password-reset and support forms (2.7): IP address, device and behaviour signals. Never inside the chat widget.
  4. E-mail – sending through our e-mail service; the provider currently used for each function (sending, the mailbox contact@lukaswojcik.com and the forwarding of e-mails to reactive.chat addresses) is named in the sub-processors list. At present this is Namecheap, Inc., Phoenix, USA, which also operates the name servers (DNS) of reactive.chat. E-mails can contain Customer data and, where a visitor requests a copy of a conversation or the e-mail channel is used without the Customer's own mail server, visitor data (3.4). In the latter case, replies to visitors are sent from our address no-reply@reactive.chat in the name "[project] via reactive.chat" with the Customer's address as reply address; the provider then receives the visitor's e-mail address and name, the subject and the text of the reply (4.6).
  5. Push services of browser makers – Google (Firebase Cloud Messaging), Mozilla, Apple and Microsoft, depending on the browser of a team member who has switched on notifications (3.10): subscription address, time and size of each message; the content (kind of event and project name, no message text) is encrypted end-to-end. The push service is determined by the team member's browser; it receives no readable content.
  6. Twilio Inc., USA – only if click-to-call by telephone is enabled (4.17): telephone numbers of visitor and agent. Not currently enabled.

5.2 Other recipients

5.3 Not recipients of personal data

6. Transfers to third countries

Our server and the AI nodes are located in Poland; the backup is stored in Poland (Warsaw). Personal data is transferred to recipients outside the EEA, or can be accessed from there, in these cases:

Safeguards: where the recipient is certified under the EU-US Data Privacy Framework, the adequacy decision of the European Commission (Art. 45 GDPR); otherwise the EU standard contractual clauses (Art. 46(2)(c) GDPR). Details per recipient are in the sub-processors list. The Telegram notifications contain no personal data, so no personal data is transferred to the United Arab Emirates. If a Customer connects a channel or integration whose provider is located outside the EEA, that transfer is the Customer's responsibility.

7. Retention overview

7.1 Backups

One period outlasts most others: the backup.

Anything deleted in the live system therefore remains inside these copies until they expire – at most 364 days after the deletion. Nothing is selectively removed from a backup: a copy is an image of one point in time. Backups are used for nothing except restoring the system after a loss. If we ever have to restore one, we will re-apply the deletions carried out since that copy was made, in particular the deletion requests of visitors and the deletions of accounts and workspaces, before the system returns to service. Since 16 October 2026 every such deletion is recorded, when it is carried out, in a deletion journal on our server – the kind of deletion, the identifiers concerned, the mode and the time, without content, e-mail addresses or IP addresses –, kept for 400 days, and a script re-applies the recorded deletions after a restore; deletions by retention period catch up at their next run. Two limits remain: a deletion requested after the copy was made that was still in its 30-day waiting period is not in the journal and must be requested again; and if the server itself were lost, the journal is only as recent as the latest backup copy, so deletions of up to the last 24 hours could not be re-applied.

7.2 Periods by category

8. Your rights

Under Art. 15 to 22 GDPR you have the right of access, the right to rectification, erasure and restriction of processing, the right to data portability and the right to object to processing based on Art. 6(1)(f) GDPR. Where processing is based on consent, you may withdraw it at any time with effect for the future. To exercise your rights:

You have the right to lodge a complaint with a supervisory authority, in particular with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warsaw, Poland, or with the authority of your habitual residence or place of work.

9. Automated decision-making and profiling

We do not make automated decisions that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR). We do not profile anyone for advertising, and we do not combine data across Customers' websites.

10. Security

We protect data with technical and organisational measures pursuant to Art. 32 GDPR, among them transport encryption (TLS 1.2 and 1.3), hashed passwords and tokens, optional two-factor authentication, role-based access control, tenant isolation, encryption of stored credentials for third-party services and of the secrets of two-factor authentication, PII scrubbing, rate limiting and automated abuse protection, and encrypted off-site backups. What the measures are, and where their limits lie, is described in the Technical and organisational measures; risks that remain are assessed in our data protection impact assessment, which we make available on request. The production installation is separate from the development installation; both run on the same server as other projects of the operator and are separated from them by directories and databases (1.1).

In the event of a personal data breach, our documented procedure provides for notifying affected Customers without undue delay and at the latest within 48 hours of becoming aware of it; where we are the controller, we notify the supervisory authority as required by Art. 33 GDPR.

11. Obligation to provide data

Providing registration and billing data is necessary to conclude and perform the contract; without it we cannot open an account. Using the chat widget on a Customer's website is voluntary; which details you enter in a chat is up to you.

12. Changes to this policy

We update this policy when the service, our sub-processors or the law change. The current version is always published at /p/privacy-policy. Customers are informed of material changes by e-mail or in the dashboard. The date below indicates the version in force; earlier versions and a summary of the changes are listed in the change log.

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

Version 2.6 replaces version 2.5 of 17 October 2026. Added: security cookie rc_csrf of the website, set on every page (2.8, 3.9, 7.2). Also changed on the same day: the separate production installation (1.1, 10); the records of processing activities and the data protection impact assessment are no longer published and are available on request (introduction, 10).

Version 2.5 replaces version 2.4 of 17 October 2026. Changed: the AI is described uniformly as our own, self-hosted AI; model names removed, the facts are unchanged (1.1, 4.4).

Version 2.4 replaces version 2.3 of 16 October 2026. Changed: acceptance of the current contract documents before ordering a paid plan (3.1); session identifier stored only as a hash (3.9).

Version 2.3 replaces version 2.2 of 12 October 2026. Corrected: language models and nodes (4.4); shortened IP address in the Smart Answer counter (4.14, 7.2); periods and deletion paths of 16 October 2026: support requests without an account (2.4), workspace deletion refused while a paid subscription is running and what remains after a deletion (3.7), expired sessions (3.9), audit-log entries without a workspace (3.11), consent records with the project or workspace (4.11), overview of periods (7.2). Supplemented on 16 October 2026: the live functions that depend on the country (live visitor list, campaigns, consent requirement for the GDPR area) derive it from the IP address with the local country database (4.2, 4.5, 4.10, 4.16). Further supplemented on 16 October 2026: declaration of registering as a business, not as a consumer (3.1, 7.2); encrypted secret of two-factor authentication and time of its confirmation in the session (3.9, 10); deletion journal and re-applying deletions after a restore (3.7, 7.1, 7.2); acceptance of the contract documents and the declaration before creating or taking over a workspace where it is missing for the current version (3.1).

Version 2.2 replaces version 2.1 of 11 October 2026. Corrected: no separate production environment (1.1, 10); notice bars of the website (2.2); loading of reCAPTCHA (2.7); telephone number for click-to-call (3.1); own data download (3.7); browser storage of the dashboard (3.9); content of push notifications (3.10); failed logins without an account (3.11); places where the IP address is stored (4.2); browser storage of the widget: rc_id, mp_ keys, rc_sig, rc_vtok and entries moved on consent (4.3); deletion of AI orders without a conversation (4.4); renewal of the live visitor list (4.5); deletion of channel identities (4.6); consent record under the retention period (4.11); re-encoding of photos (4.12); Answely, answer cache and access log for Smart Answer (4.14); translations on anonymisation (4.15); repetition lock of campaigns (4.16); local database copy (7.1); overview of periods (7.2).

Version 2.1 replaces version 2.0 of 11 October 2026. Changed: single sign-on, audit log and pseudonyms of agents (3.9, 3.11); content of push notifications (3.10); AutoQA with AI judgement only for conversations without an agent (3.11); signed e-mail address (4.2); knowledge-base files and Google Drive, bot actions with the Customer's Cal.com and Stripe, routing classification, job applications, guided flows (4.4); live visitor list (4.5); channels Telegram, SMS and e-mail in detail, API and MCP (4.6); consent requirement for visitors from the GDPR area (4.10); campaigns with new periods and the WhatsApp blocking note (4.16); calls, screen sharing and co-browsing (4.17); test runs and versions (4.20).

Version 2.6 – effective 19 October 2026.

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