Privacy Policy

Data Controller

The controller of your personal data is Exmoor Software based in Rurzyca, Poland. You can contact the controller using the following details:

• Exmoor Software
• VAT ID (NIP): 8561889653
• ul. Sosnowa 3, 72-123 Rurzyca, Poland
• E-mail: office@exmoor.pl
• Phone: (+48) 500-269-075

What data we collect

We collect personal data only to the extent necessary to provide our services:

• Contact form data (name, email address, message content)
• Data collected automatically by cookies
• Analytics data regarding website usage (only with your consent)
• The content of your conversation with the AI assistant and the details you voluntarily provide when passing a conversation summary to us (name, email address, optionally phone number)

Purposes and legal bases of processing

We process your data for the following purposes and on the following legal bases:

• Responding to your contact form inquiry and taking steps prior to entering into a contract — Art. 6(1)(b) and (f) GDPR (legitimate interest in handling correspondence).
• Direct marketing (e.g. sending an offer) — based on your voluntary consent, Art. 6(1)(a) GDPR.
• Statistical analysis of website traffic — based on your consent to analytics cookies, Art. 6(1)(a) GDPR.
• Fulfilling the controller’s legal obligations (e.g. tax) — Art. 6(1)(c) GDPR.
• Running the AI assistant conversation on the website, including answering questions about our services — Art. 6(1)(f) GDPR (legitimate interest in handling enquiries); and, for passing a conversation summary to Exmoor — Art. 6(1)(a) and (b) GDPR (consent and steps prior to a contract).
• Improving the quality and security of the AI assistant (analysis of conversation logs with contact details removed) — Art. 6(1)(f) GDPR.

AI assistant on the website

The website features an AI assistant that answers questions about our services. Using it is voluntary and browsing the site does not require it. The rules we apply:

• Please do not enter sensitive or confidential information into the chat window. A separate form inside the chat, with its own consent checkbox, is provided for sharing contact details.
• Message content is passed to the language model provider (OpenAI Ireland Ltd. and OpenAI, L.L.C., USA) solely to generate a reply. Conversation storage on the provider side is disabled and the content is not used to train models.
• This involves transferring data outside the European Economic Area, based on Standard Contractual Clauses approved by the European Commission.
• Conversation history is kept in server memory for at most 30 minutes after the last message and is then deleted.
• We record the course of the conversation (your messages and the assistant's replies). Before storing them we automatically strip content with a recognisable format: email addresses (including ones written out in words), phone numbers, tax IDs and bank account numbers.
• This filtering is a safeguard, NOT anonymisation. If you volunteer your name, company, city or other details in the conversation, they will be stored - the automation will not recognise them. Please do not type anything into the chat that you would rather not share with us. The same information is available through the contact form or by phone.
• We do this for three purposes: diagnosing failures, auditing the accuracy of answers (checking that the assistant does not mislead clients), and tuning its instructions and knowledge base. The legal basis is our legitimate interest - Art. 6(1)(f) GDPR.
• Conversation records are kept for 90 days and then deleted automatically. We do not hand these records over for training the provider's models or any external models.
• You have the right to object to this processing and to request deletion of your conversation record - write to office@exmoor.pl. Conversations are not linked to your identity, so to find a specific record we need the approximate date and topic. Either way, the record deletes itself after 90 days.
• A conversation summary reaches our inbox only if you fill in the form yourself and tick the consent box. The assistant never sends anything on its own initiative.
• The assistant’s answers are informational and do not constitute a binding offer.

Data retention

Contact form data is retained for as long as necessary to handle your inquiry and any further cooperation, and afterwards for the period required by law (e.g. for tax purposes and pursuing claims). Data processed on the basis of consent is retained until that consent is withdrawn.

Data recipients

Your data may be entrusted to trusted entities that support us technically and organizationally (e.g. hosting and email provider, analytics tools, the language model provider powering the AI assistant), only to the extent necessary for the stated purposes and under data processing agreements. We do not sell your data. Using tools such as Google Analytics may involve transferring data outside the European Economic Area, subject to appropriate safeguards.

Your rights

Under the GDPR, you have the following rights:

• Right to access your data
• Right to rectification of data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent at any time (without affecting the lawfulness of processing before withdrawal)
• Right to lodge a complaint with the President of the Personal Data Protection Office (PUODO), ul. Stawki 2, 00-193 Warsaw, Poland

Cookies and analytics

The website uses cookies. Necessary cookies are always active, while analytics cookies are only enabled after you give consent in the banner. Detailed rules are described in a separate document.

See the Cookie Policy →

Data security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, or destruction. We use SSL encryption, regular backups, and access control.

Policy changes

We reserve the right to change this Privacy Policy. Any significant changes will be published on this website.

Contact

For matters related to personal data protection, please contact us at: office@exmoor.pl.