以下のプライバシーポリシーは英語で記載されており、英語版を正本とします。
privacy policy
Draft, effective [EFFECTIVE DATE]. The plain-words version is everything above this line. This part says the same thing the way the law wants it said.
1. who we are
Spookat is run by [COMPANY NAME], a sole trader registered in Poland (jednoosobowa działalność gospodarcza), NIP [NIP], [ADDRESS] (“Spookat”, “we”). Write to us at hello@spookat.com. We have not appointed a data protection officer; we are not required to.
2. two roles
- Controller. For data about our customers, people on our waitlist and visitors of spookat.com, we decide what happens to it. This policy covers that.
- Processor. When a visitor chats through a Spookat widget on one of our customers’ sites, that customer is the controller and we process the chat on their behalf, under our data processing agreement. If you chatted with a site that uses Spookat, the site owner is your first contact. If you write to us instead, we pass your request on to them.
3. what we collect, why, and for how long
| what | why | legal basis | how long |
|---|---|---|---|
| visits to spookat.com, counted by our self-hosted Umami: page, referrer, browser, device type, country | to see which pages work | legitimate interest, Art. 6(1)(f) GDPR | aggregated statistics, no profile of you |
waitlist: your email and, if the link had one, the utm_source you came from |
to send you an invite | consent, Art. 6(1)(a) | until you sign up or ask us to delete it, and at most 12 months |
| account: email, name, and, if you sign in with GitHub, Google or Discord, your account id there and its sign-in tokens, encrypted | to run your account | contract, Art. 6(1)(b) | while the account exists, then deleted within 30 days; backups age out 30 days after that |
| billing: plan, country, invoice data we get back from Paddle | to know what you paid for and keep tax records | contract and legal obligation, Art. 6(1)(b) and (c) | as long as Polish tax and accounting law requires (generally 5 years after the end of the year) |
| support: what you send to hello@spookat.com | to help you | contract or legitimate interest | as long as the conversation needs, and at most 24 months |
Umami on spookat.com sets no cookies and stores no IP address. It counts visits with a salted hash that rotates, so it can’t recognise you over time. It runs on our own server under spookat.com/u/, so no third party sees your visit.
We use IP addresses only in memory, to deliver pages and to rate-limit abuse. We never write them to a database, a log or an error report. Cloudflare (below) carries all traffic to our sites, the widget’s included, as our network proxy and CDN, so it sees IP addresses in transit.
Card and payment details never reach us. Paddle (see below) sells the subscription as merchant of record and handles payment as an independent controller, under Paddle’s privacy policy.
4. who else gets data
We share data only with the services we need to run Spookat, each under a contract that binds them to protect it:
| who | what for | where |
|---|---|---|
| Paddle.com Market Limited | billing, merchant of record | United Kingdom |
| Postmark (ActiveCampaign, LLC) | transactional email: sign-in links, notices, reply follow-ups | United States |
| Backblaze, Inc. | encrypted backups | EU region |
| [VPS PROVIDER] | hosting | [REGION], EU |
| Cloudflare, Inc. | network proxy and CDN in front of our sites, IP addresses in transit | United States, global network |
| OpenRouter, Inc. | intent tags, only if a customer turns them on | United States |
Slack and Discord get chat messages only when a customer connects their own workspace or server to Spookat. That is the customer’s choice, and Slack’s or Discord’s terms and retention settings apply there.
Signing in with GitHub, Google or Discord is optional; an emailed link always works. If you choose one, that provider sends us your account email, whether it verified it, your name and your profile picture link, and sees that you signed in to Spookat. Its own privacy policy applies on its side. Discord is also the one a customer connects their server with, above.
Transfers outside the EEA rely on an adequacy decision (United Kingdom) or on the European Commission’s Standard Contractual Clauses (United States).
5. cookies
spookat.com sets no cookies. The Spookat widget sets no cookies either: after a visitor sends a first message, it keeps one chat token in that browser’s storage so the conversation survives a reload. The dashboard at app.spookat.com uses one strictly necessary cookie to keep you signed in.
6. your rights
You can ask us for access to your data, a copy of it (portability), to correct it, to delete it, to restrict or object to how we use it, and you can withdraw consent at any time without affecting what happened before. Write to hello@spookat.com; we answer within one month.
You can also complain to the Polish supervisory authority: Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl.
7. country lookup
We turn an IP address into a country with an offline database that runs on our own server. The IP address is never sent anywhere and never stored. IP to country data by DB-IP.com, licensed under CC BY 4.0.
8. changes
If this policy changes in a way that matters, we update this page and email customers before the change applies.