DRAFT — requires legal review. This document is not final and is not legal advice. Text in brackets is still to be confirmed.
Privacy Policy
Last updated: [TO CONFIRM: publication date]
1. Who is responsible
The controller of your personal data is KL Home OÜ, registry code 14231430, Estonia. Registered address: [TO CONFIRM: registered address].
Privacy contact: [TO CONFIRM: privacy contact email].
2. Data we process
Account data: email address, name if provided, preferred language and sign-in data.
Business data you enter: business details, website addresses, goals, budget entries, business memory facts and action plan choices.
Service data: audit results, advisor conversations, generated content and reviews.
Billing data: plan, subscription status, invoice details and billing contact. Card details are handled by Stripe; we do not store full card numbers.
Usage and technical data: usage counts, error logs and data needed to keep you signed in and remember your language.
3. Why we process it
To provide and secure the service, manage subscriptions and billing, send service emails, apply usage limits, and meet legal obligations.
Legal bases: [TO CONFIRM: legal basis for each purpose after legal review].
4. AI processing
To generate audits, advisor replies, content and reviews, relevant parts of your information are sent to AI model providers. Outputs are advisory and do not guarantee business results.
AI providers and transfer safeguards: [TO CONFIRM: list of providers, locations and safeguards].
5. Service providers
We use service providers for hosting and database, payments (Stripe), email delivery and AI processing.
Full list, locations and safeguards for transfers outside the EEA: [TO CONFIRM].
6. How long we keep data
Accounting records: invoices and other accounting source documents are kept for the period required by Estonian accounting law. [TO CONFIRM: exact period with accountant].
Other personal data: [TO CONFIRM: retention periods for account data, business data, audits, conversations, logs and backups, and what happens after account deletion]. These are separate from accounting retention.
7. Your rights
Under the GDPR you may request access to, correction or deletion of your data, restriction of or objection to processing, and data portability, and you may withdraw consent where processing is based on consent.
You may also lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or the supervisory authority in your country.
8. Cookies and local storage
We use strictly necessary cookies and browser storage to keep you signed in and remember your language choice.
Analytics or other cookies: [TO CONFIRM].
9. Security
We use access controls and keep each business’s data separate from other businesses.
10. Changes
We may update this policy and will show the date of the latest version above.
11. Contact
KL Home OÜ, registry code 14231430. Privacy contact: [TO CONFIRM: privacy contact email].