Privacy Policy

1. Controller and contact details

The controller responsible for processing your personal data in connection with ReplyGuard is:

• Akrinum OÜ
• Registration code: 16014688
• VAT ID: EE102717822
• Registered office: Harju maakond, Tallinn, Lasnamäe linnaosa, Sepapaja tn 6, 15551, Estonia
• Email: contact@akrinum.com

We process personal data in accordance with the EU General Data Protection Regulation (“GDPR”) and other applicable data protection laws.

2. Scope of this Policy

This Policy applies to personal data we collect when you visit the ReplyGuard website, create an account, use the application, receive our emails or otherwise interact with us in connection with ReplyGuard. It does not apply to third-party websites or services that may be linked from ReplyGuard.

3. Categories of personal data

We may process the following categories of personal data:

• Account data: name, email address, password hash, account settings, communication language, organisation name and similar information you provide when creating or updating your account.
• Usage data: actions within ReplyGuard (for example, login timestamps, replies generated, credit usage), device and browser information, IP address, approximate location based on IP, and log data such as access times and error logs.
• Payment data: billing address, VAT number and limited payment information required for invoicing. Full payment card details are handled by our payment providers and are not stored by us.
• Content data: email text you provide (inputs), optional context you add, and the AI-generated reply packs produced by ReplyGuard (outputs). Please do not include sensitive personal data unless necessary.
• Communication data: messages you send us (for example via email or support channels), feedback, survey responses and your marketing preferences.
• Cookie and tracking data: identifiers stored in cookies or similar technologies, which may be associated with your account and usage of the Service.

4. Purposes and legal bases

We process personal data for the following purposes and legal bases:

• Providing and operating the Service – to create and manage your account, authenticate you, generate reply packs, save your history (where applicable) and provide core functionality.
  Legal basis: performance of a contract (Article 6(1)(b) GDPR).
• Billing and accounting – to process payments, issue invoices, keep mandatory accounting records and handle related inquiries.
  Legal basis: performance of a contract and compliance with legal obligations (Article 6(1)(b) and 6(1)(c) GDPR).
• Service improvement and product development – to analyse how ReplyGuard is used, improve existing features, maintain performance and prevent abuse.
  Legal basis: our legitimate interests in improving and securing the Service (Article 6(1)(f) GDPR).
• Security, fraud prevention and misuse detection – to protect accounts, investigate suspicious activity and enforce our Terms & Conditions.
  Legal basis: legitimate interests and/or compliance with legal obligations (Article 6(1)(f) and 6(1)(c) GDPR).
• Customer support – to handle your requests, questions and complaints.
  Legal basis: performance of a contract and legitimate interests (Article 6(1)(b) and 6(1)(f) GDPR).
• Marketing and newsletters – to send product updates, feature announcements, tips and offers related to ReplyGuard and other Akrinum services.
  Legal basis: our legitimate interests or your consent where required (Article 6(1)(f) or 6(1)(a) GDPR). You can opt out at any time.
• Legal compliance – to comply with laws, regulations, court orders and requests from public authorities.
  Legal basis: compliance with legal obligations (Article 6(1)(c) GDPR).

5. Marketing communications and newsletter

When you register for ReplyGuard, we may use your email address to send you onboarding information, product tips, updates about features and occasional promotions.

You can unsubscribe from marketing emails at any time via the unsubscribe link. Even if you unsubscribe, we may still send transactional or service-critical emails (for example, security alerts, billing information, and changes to legal documents).

6. Cookies and similar technologies

We use cookies and similar technologies to operate and improve ReplyGuard, remember preferences, keep you logged in and measure aggregated usage. Depending on your jurisdiction, certain cookies may require consent, which can be managed through a cookie banner or your browser settings.

You can control cookies through your browser. However, some features of ReplyGuard may not function properly if certain cookies are disabled.

7. Recipients and data sharing

We do not sell your personal data. We may share personal data with:

• Service providers and processors – hosting, email delivery, analytics, payment processors and AI providers that help us operate ReplyGuard, bound by appropriate agreements.
• Professional advisers – lawyers, accountants and auditors where necessary.
• Public authorities – where required by law or to protect rights, users or third parties.
• Business transfers – in connection with a merger, acquisition, reorganisation or sale of assets, subject to safeguards.

8. International data transfers

Some service providers may be located outside the European Economic Area (“EEA”). Where personal data is transferred outside the EEA, we use appropriate safeguards such as adequacy decisions and/or Standard Contractual Clauses (SCCs).

You can contact us for more information about international transfers and the safeguards used.

9. Data retention

We retain personal data only for as long as necessary for the purposes described in this Policy, or as required by law.

• Account data: stored for the lifetime of your account, subject to legal retention obligations.
• Inactive accounts: if you do not generate any new reply packs for at least 6 consecutive months, we may treat your account as inactive and delete or anonymise account data, inputs and outputs from active systems, while retaining limited data in backups or for legal, accounting and fraud-prevention purposes.
• Billing and payment data: retained as required by accounting and tax laws.
• Support and communication data: retained as needed to resolve requests and for a reasonable period for reference and dispute resolution.
• Logs and security data: retained for a limited period appropriate for security monitoring and incident investigation.

10. AI models and training

We use third-party AI providers to generate outputs from your inputs. We do not use your identifiable content to train public-facing models in a way that would make your specific content recognisable to other users.

We may use aggregated or anonymised usage information to improve safety, reliability and overall quality of ReplyGuard.

11. Your rights under GDPR

If you are in the EEA, the UK, or another jurisdiction with similar rights, you may have rights including access, rectification, erasure, restriction, portability, objection and withdrawal of consent.

You can exercise your rights by contacting us at contact@akrinum.com. We may need to verify your identity before responding.

12. Complaints and supervisory authority

If you believe we process personal data in violation of applicable law, you may lodge a complaint with your local supervisory authority. In Estonia, the supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).

13. Security

We take appropriate technical and organisational measures to protect personal data. However, no online service can be completely secure, and we cannot guarantee absolute security.

14. Children

ReplyGuard is not intended for children under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact us so we can take appropriate steps.

15. Automated decision-making

ReplyGuard uses AI systems to generate reply suggestions based on your inputs. We do not use automated decision-making that produces legal effects concerning you or similarly significantly affects you as defined in Article 22 GDPR.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date at the top of this page and may provide additional notice.

Your continued use of ReplyGuard after changes become effective constitutes acknowledgment of the updated Policy.

17. Contact

If you have questions about this Privacy Policy or our data practices, contact:

Email: contact@akrinum.com