Privacy policy

The controller for the processing under this policy is WSK Software GmbH, Wupperstr. 15, 42897 Remscheid, Germany, represented by its managing director Stephan Kaupa, phone: +49 2191 5684290.

For questions about data protection and to exercise your rights, write to datenschutz@swiftpilot.ai.

This policy covers the website swiftpilot.ai, the Swiftpilot account at konto.swiftpilot.ai and the workspaces of Swiftpilot, as far as we ourselves decide on the processing: for requests through the website, the account, contract and payment, the emails we send, and the operation of the platform.

What our customers put into their workspaces or create there, we process on their behalf under Art. 28 GDPR, such as conversations with visitors of their websites, contact requests, knowledge, workflows and data from connected systems. The customer concerned is the controller for this; the details are set out in our data processing agreement. If you write to a company’s website assistant on its website, or work with Swiftpilot as an employee of a customer, please contact that company with questions about this data. Requests about it that reach us, we forward to the customer.

The Swiftpilot account and the workspaces run on servers of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, in the Nuremberg data centre. The workspaces’ files, such as documents in the knowledge and attachments, are kept encrypted in Hetzner’s object storage in Nuremberg, with a copy in the Falkenstein data centre. The backups of the databases are kept in Hetzner’s storage in the Falkenstein data centre. Hetzner processes the data on our behalf. The website also runs on servers in Germany.

When you visit, the server processes technically necessary data such as IP address, time, the page requested and the browser, to deliver the page and protect it from abuse (Art. 6(1)(f) GDPR).

We serve fonts and every other part of the page ourselves. Without your consent the page loads nothing from third parties.

The website keeps two entries in your browser’s local storage: your answer to the question about measurement (swiftpilot-consent) and, if you switch the theme, whether you want the light or the dark view (swiftpilot-theme). Both stay in your browser and are not sent to us. This storage is strictly necessary for the functions you use (§ 25(2) no. 2 TDDDG).

Only if you consent do we load Google Tag Manager of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. It loads only the services you agreed to (Art. 6(1)(a) GDPR, § 25(1) TDDDG).

Statistics: Google Analytics of Google Ireland Limited measures how the website is used, such as which pages are opened, from which page visitors come and with which device. For this, Google Analytics stores cookies in your browser. We do not allow storage for advertising with it.

Ad measurement: in addition, Google Ads of Google Ireland Limited and the LinkedIn Insight Tag of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland, recognise whether a visit or a trial request came from one of our ads. For this, both store cookies in your browser that recognise the click on an ad. LinkedIn also uses visits to the website to build audiences for our ads on LinkedIn. We do not allow personalised advertising through Google.

Google and LinkedIn may transfer data to Google LLC and LinkedIn Corporation in the USA. The basis is the EU Commission’s adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR), under which both companies are certified.

You can withdraw or narrow your consent at any time under “Cookie settings” at the bottom of the page. The page then reloads without the services you no longer agree to.

When you request a trial, we store your name, company, email address and, if given, your phone number, your message and who recommended Swiftpilot to you, along with the language and the page you sent the request from. We use these details to handle your request and set up your trial (Art. 6(1)(b) GDPR). Our sales team receives your request by email, and you receive a confirmation.

Against automated requests, your browser solves a small computing task before sending, which our server sets and checks. No data goes to third parties for this, and no cookies are set. We use your IP address only in memory to limit the number of requests; we do not store it (Art. 6(1)(f) GDPR).

We delete your request once it is dealt with, unless we have to keep it by law, at the latest a year after it was last worked on.

In the Swiftpilot account at konto.swiftpilot.ai, the administrators of an organisation manage its workspaces, members, plan and payment. For your account we store your email address, your password as a hash, your preferred language, the time of your last sign-in and the organisations you are a member of, and since when. For each organisation we store its name and its identifiers at Stripe. Invitations are valid for seven days, links to reset the password for one hour; of both we store only a hash. If an administrator invites you, we receive your email address from them.

We process this data to provide the account and to perform the contract (Art. 6(1)(b) GDPR). To protect against attacks, we limit sign-in attempts per IP address and email address; for this we hold the IP address only in memory and do not store it (Art. 6(1)(f) GDPR). Changes to an organisation, such as invitations, are recorded in a log with the email address of the person acting.

Your sign-in is held by a cookie (sp-konto) that is sent only to the account’s interface and only over encrypted connections, and that scripts in the browser cannot read. It lasts 14 days and is extended while you use the account; signing out deletes it. The account keeps language and theme in your browser’s local storage. Both are strictly necessary for the service you use (§ 25(2) no. 2 TDDDG).

When an administrator accepts the terms and the data processing agreement for the organisation, we store who accepted which version and when, with their email address, as proof that the contract was concluded (Art. 6(1)(b) and (f) GDPR). We keep this proof for three years beyond the end of the year in which the organisation’s last contract ended; then we delete the organisation with its accounts.

Your account remains until you ask for it to be deleted; write to datenschutz@swiftpilot.ai. Once it belongs to no organisation, we delete it a year after your last sign-in.

Every customer gets one or more workspaces at an address of its own on swiftpilot.ai, each with its own database. Files, such as documents in the knowledge and attachments in conversations, with the Pilot and in incoming emails, are encrypted by the workspace before it puts them into the object storage, each with a key of its own. We process their content on the customer’s behalf (see “What this policy covers”).

Members of a workspace sign in with username and password, or through a link from the Swiftpilot account that is valid for two minutes and only once. The application holds the sign-in in the browser tab’s session storage: access key, renewal key, name and permissions, along with the agent last chosen and the state of the sidebar. Signing out deletes the keys, closing the tab deletes everything. It keeps theme and language in the browser’s local storage. A workspace sets no cookies.

For operation and billing we receive only figures without content from each workspace, such as the number of conversations, the workflow runs counted and the AI budget used per model in the billing period, the number of users and of documents, and the identifier and size of stored files, not their names (Art. 6(1)(b) and (f) GDPR).

Customers can embed the Swiftpilot website assistant on their websites. In the chat window it says that an AI answers. The customer is the controller for the conversations; we process them on its behalf. So that you can follow what happens:

In the browser, the assistant keeps a random identifier (swiftpilot.browser) in local storage until you delete it, so that the server can count a browser’s open conversations, and, for the lifetime of the browser tab, the key and identifier of the current conversation. It sets no cookies.

In the customer’s workspace, the messages and answers are stored, along with, per session, the IP address and browser details (user agent), a hash of the browser’s identifier and the path of the page on which the conversation started, without parameters. What you give in a contact request, files you upload and ratings of answers are added. The IP address is used to limit the number of requests and to fend off abuse; if moderation flags a message, the sender can be blocked by IP address and session key, by default for 15 minutes or 24 hours. The workspace deletes ended blocks 90 days after they ended.

The customer decides how long conversations are kept: between 30 and 1,095 days after the conversation ends, or until it deletes them.

So that agents, the website assistant and the Pilot can answer and carry out tasks, the workspaces send the agent’s instructions, the course of the conversation with the text and images of uploaded files, and matching excerpts from the knowledge to language models of Anthropic (Anthropic Ireland, Limited, 6th Floor, South Bank House, Barrow Street, Dublin 4, D04 TR29, Ireland, with processing by Anthropic, PBC in the USA). Summaries, translations, evaluations for dashboards and the answer check also run on these models.

For searching the knowledge, OpenAI (OpenAI Ireland Ltd, 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland, with processing by OpenAI OpCo, LLC in the USA) computes embeddings of the texts in knowledge collections and of the messages for which an agent looks up knowledge. If moderation is on, which is the default, OpenAI’s moderation service checks website visitors’ messages before the assistant answers.

The data sent to these providers is processed in the USA. The transfer is based on standard contractual clauses of the EU Commission (Art. 46(2)(c) GDPR). The providers process the data on our behalf.

Organisations that book a plan pay by card through Stripe (Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland). You enter card and payment details on Stripe’s pages; they do not reach our servers. There you also enter the company name, billing address and, if any, the VAT identification number, from which Stripe calculates VAT. We send Stripe the email address, the language, the name of the workspace with its address on swiftpilot.ai and the plan chosen. We store the identifiers of the customer and the subscription at Stripe and, for customers in Germany, each invoice as an e-invoice (XRechnung) with the company, billing address, email address, VAT identification number and the last four digits of the card, for the statutory retention period; the account shows the other invoices and the card on file directly from Stripe.

The legal basis is the performance of the contract (Art. 6(1)(b) GDPR). Stripe also processes payment data under its own responsibility, for example to prevent fraud, and may transfer data to Stripe, Inc. in the USA. The basis is the EU Commission’s adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR), under which Stripe, Inc. is certified.

We keep invoices and other accounting records for the statutory retention periods (Art. 6(1)(c) GDPR in conjunction with § 257 HGB and § 147 AO).

We send emails that belong to the service: confirmations of requests, invitations, links to reset the password, the welcome to a new workspace, and notices about the trial, payments, the term, the automatic top-up, the storage used, new versions of the terms and the data processing agreement, and the deletion of data. The workspaces send emails too, such as notifications to their members, contact requests to the customer’s team and, at a visitor’s request, the transcript of their conversation. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR).

We send these emails through the mail server of Google Workspace (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), which delivers them on our behalf. If a customer has set up its own mail server, its workspace’s emails go through that server. Google may transfer data to Google LLC in the USA; the basis is the adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR), under which Google LLC is certified.

Customers can connect their workspaces to other services, such as HubSpot, Slack, Microsoft Teams, Calendly, Webex, their own databases, mailboxes and calendars, or through webhooks. Data flows there only if a customer sets up the connection; the customer decides which service receives which data. These providers are not our processors.

For signing in to these services, the Swiftpilot account passes the provider’s answer on to the workspace without storing the access keys itself. The workspace stores them encrypted.

If a customer adds its website as knowledge, the workspace fetches its pages. It identifies itself as “SwiftpilotBot” and follows the rules in the website’s robots.txt.

We collect logs, error reports and metrics of our servers and applications on our servers at Hetzner; we use no third-party services for error tracking, logs or analytics. Logs may contain IP addresses and email addresses. We use them to detect and fix faults and to fend off abuse (Art. 6(1)(f) GDPR). The applications keep their log files for at most 30 days, error reports for 90 days after they last occurred.

We back up the databases of the account and of the workspaces every night into Hetzner’s storage in the Falkenstein data centre; every backup is deleted after 90 days. New files of the workspaces are copied within an hour into a second storage in Falkenstein. Both file storages keep the previous version of a replaced or deleted file for 30 days. What you or a customer delete therefore remains in older backups for up to 90 days and, for files, as a previous version for up to 30 days.

We keep personal data for as long as needed for the purpose concerned and delete it afterwards, unless we have to keep it by law:

Trial requests: until the request is dealt with, at most a year after it was last worked on.

Swiftpilot account: until you ask for it to be deleted; once it belongs to no organisation, a year after the last sign-in.

Workspaces: when a workspace ends, or a trial ends without a booking, we keep the data for another 90 days so that the customer can resume the workspace. 14 days before deletion we remind the administrators of the organisation by email. Then we delete the workspace’s data together with its backups and its files, with all previous versions.

Deleted content: up to 90 days in the backups of the databases; deleted or replaced files for 30 days as a previous version.

Proof of acceptance of the terms and the data processing agreement, with the organisation and its accounts: three years after the end of the year in which its last contract ended. The log of changes to organisations and workspaces in our administration: three years.

Notifications to members of a workspace: 90 days.

Invoices and accounting records: for the statutory retention periods.

You have the right of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR). You can withdraw a consent at any time with effect for the future (Art. 7(3) GDPR). Write to datenschutz@swiftpilot.ai.

Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you can object at any time on grounds relating to your particular situation (Art. 21 GDPR).

You can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example with the authority responsible for us, the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestr. 2-4, 40213 Düsseldorf, Germany.

We need the details a form marks as required to handle a request or set up an account. We make no automated individual decisions under Art. 22 GDPR.