Privacy Policy
Last updated: September 30, 2026
Engineering draft, not legal advice. Before commercial launch in the EU, a lawyer should review this and fill in the bracketed placeholders (legal entity name, registered address, EU representative if applicable).
1. Data controller
Witteo ([legal entity pending incorporation], [registered address pending]) is the controller for the data described in this policy. Contact: soporte@mail.witteo.com.
2. What data we collect
From whoever registers as a business (account owner): name, email and login credentials (managed by Clerk). From each business's leads: name, email, phone, and the content of conversations with the agent — this data is uploaded by the business owner, not collected directly from public sources.
3. Legal basis for processing
Performance of a contract (providing the service to the registered business), legitimate interest (improving the product, security), and — for each business's leads — the legal basis that business declares it has when uploading those contacts (see our acceptable use policy).
4. Who we share data with (subprocessors)
Clerk (authentication), Resend (sending/receiving email), Anthropic (the AI model that generates the agent's replies), Supabase (database, hosted in the EU — eu-west-1), Vercel (hosting) and GitHub (source code, no customer data). See the detail of each in our public third-party documentation. None of these providers use your data to train their own models without your explicit consent.
5. International transfers
Some subprocessors (Anthropic, Vercel, Clerk) process data in the US. These transfers rely on the applicable safeguards (standard contractual clauses or another valid GDPR mechanism) — [pending confirmation of the exact mechanism with each provider before commercial launch].
6. How long we keep data
For as long as your account is active. If you close your account, your data and your leads' data are deleted within a reasonable timeframe, unless we must keep something for a legal obligation.
7. Your rights
Access, rectification, erasure, portability, objection and restriction of processing — write to soporte@mail.witteo.com. If you are a lead of one of our business customers and want to exercise your rights, you can write to us too and we'll route you to the right business, or contact them directly.
8. Cookies
We use technical cookies necessary for the login session (Clerk). We don't yet use analytics/advertising cookies — if we add Google Analytics or a similar tool in the future, we'll update this policy and ask for the appropriate consent before turning them on.
9. Children
The service is not directed at anyone under 16.
10. Changes to this policy
If we make significant changes, we'll announce them on the site before they take effect.
11. Contact
soporte@mail.witteo.com