Privacy Policy

The controller of personal data processed in connection with the use of the Domaluce service (the “Service”) is [legal entity or sole trader name, registered address, tax ID — to be filled in] (the “Controller”, “we”).

Contact for data protection matters: [contact email — to be filled in].

Depending on how you use the Service, we process:

• account data: email address, password (stored only as a hash, never in plain text);
• optional profile data: display name, phone, position;
• company data: name, logo, brand colors, contact details used on documents, an optional own Anthropic API key (stored encrypted, never in plain text);
• project and quote data: product names and specifications, prices, photos, end-client contact details you enter (e.g. in a project's “passport”);
• technical data: IP address, login timestamps, application error logs (see section 6).

We do not store payment card data: card payments are processed by Stripe (see section 4). From Stripe we receive only the identifiers of your Stripe customer and subscription, the plan, the billing period, the subscription status and the end date of the current period.

When you choose to sign in with Google, the Service requests a single, limited piece of information from your Google account through Google's OAuth 2.0 sign-in: your email address and whether Google has verified it. We do not request access to your Gmail, Google Drive, Google Calendar, contacts, or any other Google data or service.

We use this email address and verification status for one purpose only: to identify your existing account in the Service (if your company administrator has already invited you by that email address) and to sign you in without a password. We do not use this data for advertising, we do not sell it, and we do not share it with any third party except the subprocessors already listed in section 4, under the same terms as any other account data.

Domaluce's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

• performance of a contract (GDPR art. 6(1)(b)) — account setup and operation, providing the Service's features, technical support;
• legitimate interest (GDPR art. 6(1)(f)) — Service security, fraud prevention, error diagnostics, support staff account access to resolve a reported issue (see section 10);
• legal obligation (GDPR art. 6(1)(c)) — e.g. handling complaints, tax/accounting rules where applicable.

We use trusted providers who process data on our behalf, under data processing agreements:

• Anthropic — extracting product data from a supplier's page (AI parsing); page content is sent to Anthropic only when the user triggers this feature. If the user configured their own API key (BYOK), processing is governed by the user's own agreement with Anthropic. Anthropic also serves the optional AI assistant (section 12): the user's question and the necessary data from their projects are sent when the question is asked;
• Brevo / Resend — transactional emails (registration confirmation, password reset, team invitations, subscription renewal reminders);
• OVHcloud (OVH Groupe SA) — infrastructure provider (MinIO / database) storing files (product photos, logos) and Service data; server located in the United Kingdom;
• Cloudflare, Inc. — DNS, CDN, and attack protection (WAF, Bot Fight Mode); processes network traffic metadata (IP addresses, request headers) directed to the Service;
• Stripe — payment processing for paid plans; card details are entered directly into Stripe's payment form and are not stored by us; data shared: the company account's email address, the internal company identifier, the plan, the billing period and any account credits [Stripe contracting entity, its location and data processing agreement — to be filled in];
• Google — only if the user signs in with a Google account.

We do not sell personal data or share it with third parties for marketing purposes.

Anthropic processes data outside the EEA (United States). The transfer relies on Standard Contractual Clauses approved by the European Commission or another applicable GDPR compliance mechanism used by that provider. If you use your own API key (BYOK), your own agreement with Anthropic governs that transfer.

Our infrastructure provider's server (OVHcloud) is located in the United Kingdom, which is not formally part of the EEA. The European Commission has, however, recognised the United Kingdom as providing an adequate level of data protection (adequacy decision), so this transfer takes place in compliance with GDPR without additional safeguards.

Payment data processed by Stripe (see section 4) may be transferred outside the EEA. [where Stripe processes the data and the transfer mechanism — to be filled in]

• account and company data — until the account is deleted by the user or the Controller, per the Terms;
• technical error log (ErrorLog) — up to 90 days, then automatically deleted;
• support-access log (impersonation) — kept as an audit record for accountability and security purposes;
• AI assistant conversation text — up to 30 days; assistant usage metadata (no content) — up to 24 months (see section 12);
• database backups — per the infrastructure's backup rotation cycle.

You have the right to access, rectify, erase, restrict the processing of, and port your data, and to object to processing based on legitimate interest. To exercise these rights, write to the address in section 1.

You also have the right to lodge a complaint with your national data protection authority (in Poland: the President of the Personal Data Protection Office, UODO) if you believe the processing of your data violates GDPR.

The Service uses only strictly necessary cookies (keeping a logged-in user's session) and local browser storage for display preferences (e.g. light/dark theme, selected language, the ID of the last AI-assistant conversation in tab session storage). We do not use advertising or third-party analytics cookies.

The Domaluce extension for Chrome serves a single purpose: adding products to the Service directly from a supplier's page. To do this, the extension processes:

• the content of the open product page (HTML and URL) — sent to the Service only when the user clicks the button to recognise product data; used to read the product name, price, photos and specifications, including with AI (see section 4);
• a screenshot of a selected screen area — only when the user selects the area themselves; sent to the Service as a product photo;
• sign-in and session data — a session token and basic account details (email address, company, role) stored locally in the extension's storage; when signing in with Google, the extension receives only the email address from Google;
• settings — the selected interface language.

The extension does not track browsing history, does not read pages on which the user has not opened it, shows no ads and shares no data with anyone other than the subprocessors listed in section 4. Data is sent only to the Service over an encrypted connection (HTTPS) and is never sold or used for purposes unrelated to the extension's function. The use of information complies with the Chrome Web Store User Data Policy, including the Limited Use requirements.

Signing out removes the session token and account details from the extension's storage; uninstalling the extension removes all of its local data. Products and photos added to the Service are subject to the retention rules described in section 6.

Designated staff on our side may, solely to diagnose a reported technical issue, temporarily access a user's account view (“log in as”). Every such access is logged (who, when, which account) and time-limited. We do not use this feature to browse accounts without a genuine support need.

The integration features (project import from a file, inbound addresses and API keys, outgoing webhooks, client emails) move the User's end-client data, in particular name, phone number, email address and site address, between the Service and the systems the User chooses (for example their CRM):

• file import — an uploaded CSV or Excel file is parsed into a table kept in the Service for at most 24 hours (and removed as soon as the import finishes or is undone); only a report with counts and reasons for skipped rows remains in the history;
• AI column hint — at the User's request, only the headers of unmatched columns and up to 3 example rows of those columns are sent to the AI provider (see section 4);
• inbound addresses and API — data sent by the User's system is written to the project; the request log (kept for 30 days) contains only the result, the external identifier and the reason for a rejection, never the request body;
• outgoing webhooks — project events (including client contact details and the deadline) are sent to the address chosen by the User; we keep event contents for up to 30 days for retries and the delivery history. Events never contain cost prices or margin;
• client emails — an email with a specification link or a quote is sent through the email provider (see section 4) to the address chosen by the User; we record the recipient, type, result and time of sending (not the content). At the User's request a copy (BCC) also goes to their CRM address.

The User is responsible for having a legal basis to pass their clients' data to these features and systems.

The AI assistant is available on all plans and is on by default. A company account administrator can turn it off at any time in Settings (Company → AI assistant); once it is off, no data is sent to the AI provider. When turning it back on, the administrator confirms that the data described below will be sent to an external AI provider. Data is sent only when a user asks the assistant a question. When you talk to the assistant you are told that it is an artificial intelligence system (Article 50(1) of Regulation (EU) 2024/1689), and its replies are marked as AI-generated.

What data is sent. The text of your question and — only as far as needed to answer and only from projects you have access to in the Service — project names, the client's name and address, deadlines, item names, catalogue numbers and manufacturers, quantities, client prices, approval statuses, client comments and change-log entries. We do not send clients' phone numbers or email addresses, passwords or API keys. Purchase prices and margins are not sent unless the company administrator separately enables this (with a separate confirmation).

Roles and legal basis. Data contained in projects (including end-clients' data) is processed on behalf of the company that is the Service user, under a data processing agreement (Article 28 GDPR) available on request. For the user's account data, the basis is performance of the contract (Article 6(1)(b) GDPR — a feature ordered by the company), and for security and usage limits — legitimate interest (Article 6(1)(f) GDPR). As controller of its end-clients' data, the company is responsible for having a legal basis for such processing, for informing its staff and clients about it, and for not entering special-category data (Article 9 GDPR) in questions.

Recipient and transfer outside the EEA. Anthropic, PBC (United States) — as a subprocessor (see sections 4 and 5). Under the provider's API terms, data sent through the API is not used by default to train its models; retention on the provider's side is governed by its current data processing agreement [provider retention period and verification date — to be filled in]. If the company uses its own API key (BYOK), its agreement with the provider applies.

How long we keep it. Conversation text (questions and answers) — up to 30 days, or until you delete it earlier, your account is deactivated, or you lose access to the relevant project (related messages are then deleted). The assistant does not store the results of reading project data. Usage metadata (date, token counts, project identifiers, no conversation content) — up to 24 months, for billing, limits and security.

Safeguards. The assistant sees only what the signed-in user can see (access to projects is checked on every request), only reads data and never changes or sends anything. A company administrator cannot read other people's conversations, and the assistant is disabled in technical-support sessions. The assistant makes no decisions that produce legal effects or similarly significantly affect individuals (Article 22 GDPR).

You have the rights described in section 7, including the right to delete a conversation in the assistant panel. The assistant's answers may be wrong — verify important data in the Service.

Passwords are stored hashed (bcrypt). A user's own Anthropic API key (BYOK) is encrypted with AES-256-GCM before being stored and is never returned in plain form by the API. Communication with the Service uses an encrypted connection (HTTPS) in production.

We may update this Policy, in particular following changes to the Service's functionality or applicable law. We will notify you of material changes by email or via a notice in the Service.

For questions about this Policy or the processing of your personal data, contact us at: [contact email — to be filled in].