LunieAI

Data Processing Agreement

Last updated: 9 September 2026

This document is not finalIt accurately describes how the software handles data, but the operating company’s registered details are still to be confirmed and it has not yet been reviewed by a legal adviser. It should not be relied on as published policy until both are done.

This agreement applies where you use LunieAI to run a chatbot that members of the public interact with. In that situation you are the data controller for those conversations and [company legal name to be confirmed] is your processor. It forms part of our Terms of Service and takes effect when you start using the service.

1. Subject matter and duration

We process personal data on your behalf so that we can operate your chatbot: store conversations, retrieve relevant passages from content you supply, and generate replies. Processing continues for as long as your account is open, and ends when you delete the data, delete your account, or the retention period you set expires.

2. Nature and purpose

Storage, retrieval, indexing and transmission to the AI provider named in our subprocessor list, for the sole purpose of answering your visitors’ questions.

3. Categories of data and data subjects

  • Data subjects: visitors to your website who use your chatbot.
  • Personal data: the content of the messages they send, and a randomly generated session identifier. We do not store their IP address, browser details, or any cross-session identifier.
  • Special category data: not requested and not expected. You must not configure a chatbot to solicit it.

4. Our obligations

  • We process personal data only on your documented instructions — using the service is that instruction — unless required otherwise by law, in which case we will tell you first unless the law prevents us.
  • Everyone with access is bound by confidentiality obligations.
  • We implement the security measures described in section 6.
  • We assist you in responding to requests from your visitors, and with your obligations on security, breach notification and impact assessments.
  • We delete data as described in section 7.
  • We make available the information needed to demonstrate compliance with Art. 28 and allow reasonable audits.

5. Subprocessors

You give general authorisation for us to use the subprocessors listed on our subprocessor page. We will give you reasonable notice before adding or replacing one, and you may object on reasonable data protection grounds. Each is bound by obligations equivalent to those in this agreement, and we remain responsible to you for their performance.

Note that generating a reply requires sending message content to our AI provider, which is located in the United States. That transfer relies on the safeguards described on the subprocessor page.

6. Security

The measures in place, described accurately rather than generically:

  • Data is encrypted in transit.
  • Access is enforced on the server against an authenticated session, and scoped to the account that owns the data. The browser has no direct database access.
  • Credentials and API keys are stored hashed, never in plain text.
  • Message content is not written to application logs.
  • Rate limiting protects against automated abuse.

7. Assisting with visitor requests

Your dashboard gives you the tools to answer a request from one of your visitors directly, without needing to contact us:

  • Find a conversation by session ID or message content on the Conversations page.
  • Export it as JSON, to satisfy an access request.
  • Delete it permanently, along with all of its messages.
  • Set a retention period per chatbot, after which conversations are deleted automatically.

Visitors can also delete their own conversation from the chat widget while it is still open. If you need help with a request you cannot action yourself, contact us at [privacy contact email to be confirmed].

8. Deletion and return

Deleting a conversation, a chatbot or your account removes the underlying data — including messages, uploaded files and search indexes — permanently and across all systems. It is not recoverable afterwards, so export anything you need first.

We retain a minimal record that a deletion request was made and completed (an identifier, an email address and a timestamp) because we must be able to demonstrate that we honoured it.

9. Personal data breaches

If we become aware of a breach affecting personal data we process for you, we will notify you without undue delay, with the information you need to meet your own notification obligations.

10. Contact

Questions about this agreement, or a request for a signed copy, can be sent to [privacy contact email to be confirmed].