Privacy and cookies policy

This is an English rendering for convenience. The binding version is the Polish one, available at aivatary.com/pl/prywatnosc/. In case of discrepancy, the Polish text prevails.

Part I. In short

This part is a summary and does not replace the detail in Part II.

Who processes the data. MH Daniel Możdżyński, ul. Sędziwoja 49 lok. 3, 61-063 Poznań, Poland. For all data matters: contact@aivatary.com.

Why. To run your account, let the agent answer questions from your customers, settle payments, show how the service works in the test drive, keep the platform secure and, with consent, send product information.

Three things worth knowing before you start:

1. Conversation content is sent to a language model provider. Without it the agent could not phrase an answer. The contract is with an entity established in the European Union; details are in section 9 and in the separate subprocessor register.
2. For conversations with your customers we are a processor, not a controller. You decide what goes into the knowledge base and how long conversations are kept. Section 2 sets out the split of roles.
3. The agent answers only from content you published. An answer without coverage in the sources is never sent, so the scope of processing is set by your knowledge base, not by the model's training data.

What we do not do. We do not sell data. We do not profile anyone for advertising. We make no decisions producing legal effects solely by automated means. This website runs no analytics and no advertising tool, which is why there is no consent banner here: there is nothing to declare.

Test drive. When you use the Ada test drive on this site, we are the controller of the data: the address and content of the indicated website, the chat and, if you order the call, the number and the record of consent. The test drive content disappears at the latest after 7 days and the number one day after the call. Details: Part III.

Part II. Detail

1. Controller and contact

1. The controller is Daniel Możdżyński, a sole trader operating as MH Daniel Możdżyński, ul. Sędziwoja 49 lok. 3, 61-063 Poznań, Poland, tax number (NIP) 8522140767, statistical number (REGON) 811228847, entered in the Polish Central Register and Information on Business Activity (CEIDG).
2. For all matters concerning personal data, write to contact@aivatary.com or to the registered address.
3. We have not appointed a data protection officer. For all matters concerning personal data, use the address given in point 2.

2. Scope and our two roles

1. This policy covers aivatary.com, the panel at app.aivatary.com and the widget our customers embed on their own sites.
2. We act in two different roles, and that distinction is the most important thing in this document:

3. For the second role the basis is the data processing agreement. A person whose data appeared in a conversation with our customer's agent addresses their request to that customer, and we provide technical support.

3. Whose data we process

• People creating and running an account in the panel.
• Operators granted access to the conversation inbox by our customer.
• People writing to our contact address or talking to Ada on this site.
• End customers of our customers, to the extent their data appears in a conversation.
• People using the Ada test drive and people whose data is published on websites indicated for a test drive (Part III).

4. Where the data comes from

• Directly from you, when creating an account, in correspondence and in conversation with the agent.
• From our customer, when they grant access to an operator.
• From automatic platform records, described in section 5.
• From public websites indicated for a test drive (Part III).

5. What data we process

The audit log does not store conversation content. Entries carry identifiers, codes and metrics; a person's data appears only where it is the subject of the entry (for example the address or number a data rights request or a complaint came from, the address of a person invited to the team, or the recipient of a conversation summary). In the agent's decision trace, confirmation cards and handoffs, national identification numbers (checksum verified), IBAN numbers (mod 97 verified), phone numbers, email addresses, card numbers and tokens are replaced with markers before the event reaches the log at all.

Audio from a voice session serves one purpose only, conducting the conversation: turning speech into text and synthesising the reply. We do not subject it to analysis of voice characteristics for the purpose of uniquely identifying a natural person, so we do not process biometric data within the meaning of Article 4(14) GDPR in this way. Participants in a session are told apart by a participant identifier, not by the sound of their voice.

6. Purposes and legal bases

7. Legitimate interests

Where we rely on legitimate interest, we balanced it against the rights of the people concerned. The interest is keeping a working and secure platform, defending against abuse, and being able to show how the agent reached a particular decision. The scope is limited technically: the audit log does not store conversation content and carries a person's data only where it is the subject of the entry, and technical records are not used to build a profile of anyone. A right to object applies, described in section 13.

8. Artificial intelligence systems

The agent uses a language model, and voice sessions additionally use speech recognition and synthesis. The scope of that processing, what happens to content sent to the model, and the rules of human oversight are set out in a separate document: the AI systems notice. It carries its own version and date, so changing a model provider does not force a change to the whole privacy policy.

9. Recipients

1. We entrust data to entities providing our infrastructure and specific platform functions: the language model provider, speech synthesis, message delivery and the data centre operator.
2. The current list of those entities, with the scope of entrustment, place of processing and the basis for any transfer outside the European Economic Area, is published separately as the subprocessor register.
3. That register carries its own version number and date. Changing a provider updates the register, not this policy, so the policy version does not move for reasons unrelated to your rights.
4. Recipients of data from the test drive, where we are the controller, are named in Part III.
5. Beyond that, data may reach entities authorised under statute, our accountants and our legal advisers, to the extent necessary to defend claims.

10. Transfers outside the European Economic Area

1. Application servers and the database run in the European Union, in Warsaw.
2. Some functions, however, use providers whose parent companies are established outside the European Economic Area. So we do not claim that no data ever leaves that area. For each such case the subprocessor register states the country of processing and the transfer basis, that is an adequacy decision under Article 45 GDPR or standard contractual clauses under Article 46(2)(c) GDPR together with a transfer impact assessment.

11. Retention

12. What happens when the contract ends

1. We delete or return the data entrusted by our customer, according to their decision and the data processing agreement.
2. The knowledge base belongs to our customer and is exported in an open format on request.
3. We keep only what statute requires, primarily accounting records, and what is needed to defend claims.

13. Your rights

1. We respond without undue delay and no later than one month. For complex matters we may extend that by two months, telling you beforehand.
2. If we cannot confirm the identity of the person making the request, we ask for more information. Not to obstruct, but so that we do not hand data to someone else.
3. If the request concerns a conversation held by our customer's agent, we pass it to that customer, because they are the controller, and we tell the requester that we did.

14. Marketing

Product information goes only to people who consented. Consent can be withdrawn at any time, and withdrawal does not affect the lawfulness of processing before it. We do not pass email addresses to third parties for marketing.

15. Automated decisions and profiling

We make no decisions about anyone based solely on automated processing that would produce legal effects or similarly significantly affect them. The agent phrases answers, but every operation that changes data requires human approval, described on the confirmation cards page. We do not profile anyone for advertising or behavioural marketing.

Enquiry fit scoring. When you book a demo through the chat window on this site, we compute an auxiliary fit score. We use only the data you entered in the booking form: the domain of your e-mail address, the company name, the company website address and the text of the "what would you like to see" field. The content of your conversation with the assistant is not used for this.

The score considers whether the address comes from a company domain or a free mailbox, whether a website was given and whether it matches the e-mail domain, and whether the company name or the description contains words we flagged in advance as relevant or disqualifying.

The score serves only to prepare the person running the demo and to set the order of contact. On its own it causes no refusal of a meeting, no refusal to enter a contract, no price change and no other legal or similarly significant effect. A human decides how the enquiry is handled. The score is not stored: we compute it each time from current data, and we keep only the form data itself, together with the booking.

The basis is our legitimate interest in handling sales enquiries efficiently (Article 6(1)(f) GDPR). You have the right to object to this processing (Article 21 GDPR); a message to contact@aivatary.com is enough.

16. Security

We apply technical and organisational measures appropriate to the risk: encrypted connections, encrypted channel credentials in the database, separation of organisations at query level, role based access control, an append only audit log, and protection of content import against reaching internal network addresses. Details are on the security page.

17. Cookies and browser storage

1. This site sets no cookies. No Google Analytics, no Tag Manager, no advertising pixel, no other analytics or marketing tool. We say so explicitly, because the absence of a tool is as much information as its presence.
2. The site uses browser storage as described in the table below. Persistent storage (localStorage) keeps a value until it is removed or the stated period elapses; session storage (sessionStorage) disappears when the tab is closed. None of these values is sent to our server.

   Entry	Where	What it holds	When it appears	How long
   theme	persistent	the light or dark choice	when the theme is changed	indefinitely
   caip:widget:memo2	persistent	your own chat messages (up to 12, 400 characters each); the assistant's replies are not stored	at your first message	6 hours from the last message, cleared on a timer
   caip:widget:resume	persistent	the label of the page the assistant opened (up to 80 characters), no content	on a move suggested by the assistant	5 minutes
   caip:widget:teaser	persistent	the timestamp of dismissing the invitation bubble	when you click to dismiss it	30 days
   caip:widget:closed	session	that the chat window was closed	on closing the window	until the tab is closed
   caip:widget:voice-notice	session	that you read the notice shown before the microphone is switched on	after clicking "Start the conversation" in that notice	until the tab is closed
   caip:widget:memo-off	session	that you opted out of remembering the chat	after clicking "delete from this browser"	until the tab is closed
   caip:test-drive:session	session	the identifier and the secret of your test drive on the "Try it on your website" page, so a page refresh does not lose it; no website address and no messages	after starting a test drive	until the tab is closed, or earlier when you delete the test drive

   The chat record appears only once you write something to the assistant. Opening the chat window, including automatically, stores nothing. The chat window carries a "Delete from this browser" button; after using it we store nothing for the rest of the visit.
3. The conversation with Ada started from this page connects to app.aivatary.com, our own infrastructure. We load no assets from a content delivery network or another company's servers, which is why there is no consent banner.
4. The panel at app.aivatary.com sets no cookies. The authentication token is held in the browser tab's memory and in session storage, and disappears when the session ends. The storage is strictly necessary to keep you signed in, so it is not subject to consent.
5. Browser settings let you clear stored values at any time. Removing the theme entry restores the default theme.

18. Changes to this policy

1. We announce material changes in advance by email and by a notice in the panel.
2. Every release carries a version number and an effective date, shown at the top of the document.
3. A change to the subprocessor register does not change this policy's version number, because the register is a separate document with its own version.
4. Version 1.3 adds Part III on the Ada test drive, a paragraph about it in Part I, rows referring to it in sections 2 to 6, 9 and 11, and a row in the browser storage table in section 17. The rules for processing data in the panel, in our customers' widget and in the other functions do not change.

Part III. The Ada test drive

On the "Try Ada on your own website" page you can check, without an account, how Ada would answer customers of the company whose website you indicate: in the chat window on this site and, when the phone is available, in a single automated phone call. The rules of the service itself are set out in the test drive terms. This part describes the data: who processes it, where it comes from, why, who receives it and how long we keep it.

1. Controller

The controller of all data described in this part is MH Daniel Możdżyński (section 1). We run the test drive on our own account, as a presentation of our service. The fact that it technically runs in a separate, single-use data space does not make us a processor there, nor does it make the company whose website you indicated a controller. We pass nothing to that company.

2. What data we process and where it comes from

In the test drive Ada answers only from content fetched from the indicated website, and we publish that content automatically, without human editing. See the AI systems notice.

3. Purposes and legal bases

Consent to the call covers only this one demonstration and does not cover any later marketing calls. Giving the number is voluntary, but without it there is no call; the chat works without a number.

4. Recipients

For part of the data, in particular data about calls and messages, Twilio acts as a separate controller under its own terms. The call and the SMS also pass through the operator of the network your number belongs to, which processes call data as a separate controller. We do not use test drive data to train models.

5. Call audio and data held by providers

We do not store audio recordings of the call in our systems: the audio passes through our server in real time and is not stored. We delete the call transcript right after the call ends and, if you gave an email address, right after sending the transcript to it.

The providers in point 4 do, however, keep the data passed to them for their own periods, independent of ours: by default OpenAI keeps data sent to its services, voice services included, in safety logs for up to 30 days; ElevenLabs by default stores the text sent for synthesis and the generated audio unless a no-retention mode is active for the account; Twilio keeps numbers, call data and messages for periods set by its own terms. So we do not claim that the call audio is never stored anywhere.

6. Retention

Data past its period is removed by an automated job that runs every hour, so it disappears at the latest one hour after the deadline.

7. Deleting the test drive and cancelling the call

1. The "End the test drive and delete its content" button immediately deletes the test drive space, that is the content fetched from the website, the chat and the assistant's settings, as well as the website address, the company name, the phone number and the email address. What remains are the hashes for the limits, the call data and the record of consent to the call without the full number, for the periods in point 6.
2. You can cancel the call before it is placed with the "Cancel the call" button; that withdraws consent. You can end the call at any time by hanging up.
3. After no answer or a busy line, we call again only at your separate request.

8. Your rights

You have the rights described in section 13, including the right to object to processing based on legitimate interest and to withdraw consent to the call. Withdrawing consent does not affect the lawfulness of processing before the withdrawal. We keep the record of consent after it is withdrawn as well, for the period in point 6, because it serves to show that the call took place with consent. In the test drive we make no decisions based solely on automated processing and we do not profile anyone.

9. Information for people whose data is on indicated websites

If your data, for example your name, position or work phone number, is published on the website of a company indicated for a test drive, we may have fetched it together with the content of that website. We address this information to you under Article 14 GDPR.

• Controller: MH Daniel Możdżyński, contact contact@aivatary.com.
• Source of the data: a publicly available website indicated by a person using the test drive.
• Categories of data: data contained in the content of the fetched pages, without pages about people and with PESEL, Polish bank account and card numbers replaced by markers (point 2).
• Purpose and basis: showing how the service works on the content of that website, Art. 6(1)(f) GDPR.
• Balancing of interests: we fetch only public pages, skip pages about people and mask identifiers before the content reaches the model. We publish nothing, pass nothing to the company or to anyone other than the recipients in point 4, build no profiles or contact lists from this data, and delete everything at the latest after 7 days.
• Recipients and period: points 4 and 6.
• Rights: section 13, in particular the right to object under Article 21 GDPR. An email to contact@aivatary.com naming the website is enough.

We do not notify each of these people individually. We fetch the website content without establishing whom it concerns, and we deliberately skip pages about people. To notify these people we would first have to find them in the fetched content and establish their contact details, that is process more data about them than the test drive itself does. That is why we make this information publicly available here (Article 14(5)(b) GDPR).