Privacy Policy

1. Data Controller

The data controller for your personal data is:

2. Data We Collect

We collect the following categories of personal data:

Account Information

• Email address
• Name (optional)
• Account preferences and settings

Usage Data

• Log data (IP address, browser type, access times)
• Feature usage patterns
• Device information

Service-Specific Data

• PupGatchi: Pet health logs, behavior records, feeding schedules
• Legal Agent IT: Search queries, saved research (not stored on our servers)
• Gym Coach AI: Exercise logs, anonymized video analysis data

3. Legal Basis for Processing

Under the EU General Data Protection Regulation (GDPR), we process your data based on:

• Contract: To provide the Services you subscribed to
• Legitimate Interest: To improve our Services and ensure security
• Consent: For marketing communications (you may withdraw anytime)
• Legal Obligation: To comply with applicable laws

4. How We Use Your Data

We use your personal data to:

• Provide and maintain the Services
• Process your subscription payments
• Send service-related communications
• Respond to support requests
• Analyze usage to improve our Services
• Detect and prevent fraud or abuse

5. Data Sharing

We share your data with the following third parties:

• Lemon Squeezy: Payment processing (Merchant of Record)
• Hetzner: Cloud hosting (servers located in EU)
• AI Model Providers: Anonymized data for AI processing (Claude, GPT-4, etc.)

We do not sell your personal data to third parties.

6. Data Retention

We retain your personal data for as long as your account is active. After account deletion, we retain data for:

• Transaction records: 10 years (Italian tax law)
• Usage logs: 90 days
• Support tickets: 3 years

7. Your Rights (GDPR)

Under GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we process your data
• Portability: Receive your data in a machine-readable format
• Objection: Object to certain processing activities
• Withdraw Consent: Where processing is based on consent

To exercise these rights, contact us at privacy@theagentfactory.studio.

8. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encryption in transit (TLS 1.3) and at rest
• Regular security audits
• Access controls and authentication
• Data minimization practices

9. International Transfers

Our primary servers are located in the European Union (Germany). When data is transferred outside the EU (e.g., to AI providers), we ensure appropriate safeguards through Standard Contractual Clauses or adequacy decisions.

10. Cookies

We use minimal, essential cookies for:

• Session management
• Authentication state
• User preferences

We do not use tracking or advertising cookies.

11. Children's Privacy

Our Services are not directed to children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us data, please contact us for removal.

12. Complaints

If you are unsatisfied with our handling of your data, you have the right to lodge a complaint with the Italian Data Protection Authority:

13. Contact

For privacy-related inquiries: