Informativa sulla privacy

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This notice explains what personal data ChatPuff processes, why, for how long, and what your rights are. ChatPuff is provided by Nikolaos Sarafoudis, 8 Nikolaou Plastira Str, 56334, Thessaloniki, Greece ("ChatPuff", "we"). Questions about privacy go to support@chatpuff.com.

It covers three groups of people: the merchants and staff who use ChatPuff (section 1), the shop customers who chat through the ChatPuff widget on a merchant's shop (section 2), and visitors of chatpuff.com (section 3). Sections 4 to 8 apply to everyone.

1. Merchants and their team

For the accounts of merchants and their staff, ChatPuff is the controller.

What we process and why

DataPurposeLawful basisKept for
Name, the name you choose to show to customers, email address, password (stored as a hash), interface languageYour account, sign-in, invitations, the emails the Service sends youPerformance of the contract (Art. 6(1)(b) GDPR)While the account exists, then as in section 5
Organization name, shops, domains, settings, rolesProviding the Service to your organizationContractWhile the account exists
Sign-in sessions, IP address, time, device typeSecurity of the account, detecting abuse, rate limitsLegitimate interest in a secure service (Art. 6(1)(f))Sessions until they end; audit records 6 months
Native app sign-ins: the device's name and platform (iOS or Android), the phone's push notification token and your notification choicesSigning in to the native apps and sending you the notifications you choseContractThe push token until you sign out or the sign-in ends; the sign-in record 30 days after it ends
Your choice about ChatPuff's newsletter: when you asked for it, when you stopped it, and the version of the text you agreed toSending you news about new versions and features, only if you asked for itConsent, which you withdraw on your account page or with the link in every newsletterWhile your account exists
Audit records of administrative actions (who changed what, when, from which address), including our support staff's access to a shop's conversationsAccountability of team changes, support and security investigationsLegitimate interest; legal obligation where applicable6 months
Billing details (the name, address, country and VAT number on your receipts and invoices), invoices, payment status (card data is handled by our payment provider and never reaches our servers)Subscriptions, receipts and invoices, tax records, which our e-invoicing provider transmits to the Greek tax authority (myDATA)Contract; legal obligation (accounting and tax law)The statutory period for accounting records in Greece
Support emailsAnswering your requestsContract; legitimate interest2 years after the last exchange
Your own work in the Service: per day, the chats you accepted and resolved, your replies, how long customers waited for them, and the ratings customers gave the chats you handledShowing these numbers on the dashboard to you and to the Owners and Admins of the shops you work inContract13 months, or until your access to the shop ends
Bug reports you send from the dashboard: what you write, the screenshot you attach, the page you were on, your browser, the version and the request referenceFinding and fixing the problem you reportContract; legitimate interest in a working service1 year after the report is closed
Technical logs (route names, timings, errors, correlation IDs; never message texts, names or email addresses), and error reports emailed to our administrator with the error and the request referenceDiagnosing problemsLegitimate interest30 days

Emails we send to merchants and staff: account and security emails (confirmation, password reset, the code that confirms a new email address, invitations, changes to the team), service notices, including planned maintenance, alerts about chats waiting for an answer, also when your shop opens with chats waiting, and billing emails with their receipts and invoices. In the native apps, the notifications you allow tell you about waiting chats, new messages and transfers, and a notice of planned maintenance reaches every signed-in app; they carry no names and no message texts. Notices from ChatPuff, and from your organization's Owners to its team, appear under the bell in the dashboard and the apps; we record which ones you have read, so that each is shown as new only once. The dashboard uses only the cookies needed to sign you in: the session cookie and, if you tick "Keep me signed in", a cookie that resumes your sign-in for 30 days. We do not send marketing emails to your account address without your consent: ChatPuff's newsletter, with news about new versions and features, goes only to the members who asked for it on sign-up or on their account page, and stops with the switch there or with the link in every newsletter.

2. Customers of a merchant's shop

When you chat through the ChatPuff widget on an online shop, the merchant who runs that shop is the controller of your data, and ChatPuff processes it on the merchant's behalf as a processor, under a data processing agreement. The merchant's own privacy policy, linked in the chat window, tells you why the shop uses chat and what your rights are. You exercise your rights with the merchant; we help the merchant answer.

What ChatPuff processes for the merchant

  • The name and email address you type before your first message, or, when you are signed in to the shop, the name, email address and customer number the shop passes to the widget so that you do not have to type them.
  • The messages you and the shop's team exchange, and their times.
  • Images and PDF files you send, where the shop's plan allows it. Every file is scanned for malware on our servers before anyone sees it.
  • The address and title of the shop page you are on, and the product it shows, sent with your messages and when you open another page during the chat, so that the shop's team and the assistant know what you are looking at.
  • Where the shop turns it on, the text you are typing before you send it, which the shop's team sees marked "Not sent yet". It is kept only in the server's memory while it stays in your message field, at most 45 seconds after your last change, and is never stored or logged.
  • Codes we email to the address you gave when you ask to find your earlier chats, and codes we email to the address on an order when you ask about that order. When you verify an order, ChatPuff asks the shop for its details each time you look at it and keeps no copy.
  • A random visitor token stored in your browser, so that you find your conversation again in the same browser. It identifies your browser to ChatPuff only, and it is never used for advertising.
  • The language of your browser, to show the chat in your language.
  • Your IP address and browser type, for security, rate limits and abuse prevention only. They are not kept with your conversation.
  • When the merchant uses AI answers: your messages, the page you are on, the details of orders you verified in the chat and the shop knowledge are sent to the AI provider named in section 6 to generate the answer. Files are never sent. Providers we use do not train their models on this data.
  • The rating you give after a resolved chat (thumbs up or down, and a comment if you leave one), kept with the conversation and shown to the shop's team.
  • Where the shop offers it and you tick the box, your sign-up to the shop's newsletter: your name and email address, the exact text you agreed to, and the times you agreed, confirmed and, if you do, unsubscribed. We email you a confirmation link; you are on the list only once you click it, and every such email carries an unsubscribe link. The shop takes its list into its own mailing tool; ChatPuff sends no newsletter itself.

Conversations are kept for the retention period the merchant chooses, by default 6 months after a conversation is resolved, and are then deleted. A newsletter sign-up never confirmed is deleted after 7 days, an address that unsubscribed 30 days after it left, and a confirmed sign-up stays as long as the shop keeps its list. Emails ChatPuff sends to customers on the merchant's behalf (a link to continue a conversation, verification codes, the newsletter confirmation) come from ChatPuff addresses that are not monitored; replies to them are not read.

3. Visitors of chatpuff.com

Our web server keeps access logs with IP addresses for 30 days, for security. The sign-in and sign-up pages of the dashboard use Cloudflare Turnstile to block automated abuse; it sets no advertising cookies.

The chat on our pages ("Questions about ChatPuff? Ask here") is our own ChatPuff widget. It loads nothing from third parties and sets no cookie: once you start a chat it keeps a chat key in your browser's storage, and once per visit it notes there that it showed you its greeting. In the chat, our assistant answers by itself from our public pages and help guides; no person takes over, and anyone who asks for one is pointed to our contact page. We keep what you write, the name and email address you give and the page you are on for up to six months, to answer you and to look after the service; our team may read the chats, and the assistant's provider, Google Cloud (Vertex AI, in the EU), processes them for us as a processor. The lawful basis is the service you ask for (Article 6(1)(b) GDPR).

While sign-up is limited to a number of accounts, you may leave your email address on the sign-up page to be told when a place opens. We use it only for that, in the language of the page you left it on, and we delete it when you create an account, or a year after you left it.

chatpuff.com asks for your consent before it loads anything that is not necessary, and it works the same whatever you choose. Your choice is kept for 6 months; you can change it at any time under "Cookie settings" at the bottom of every page, and taking your consent back deletes the cookies below. Google Tag Manager, which loads the analytics and marketing tools, itself loads only after you accept one of them.

CategoryWhat and whyCookies and how longLawful basis
NecessaryYour cookie choice; and, if you choose one, your light or dark appearance, kept in your browser's storage and never sent to us; and, if you use the chat on our pages, its chat key and that its greeting was shown, in the same storage (above)cp_consent, 6 monthsNecessary for the service you ask for (Article 4(5) of Law 3471/2006)
AnalyticsGoogle Analytics 4 through Google Tag Manager (Google Ireland Limited): the pages visited, how visitors arrived, their approximate location and type of device, without names_ga and _ga_…, up to 13 monthsConsent (Article 6(1)(a) GDPR)
Marketing, when we advertiseGoogle Ads (Google Ireland Limited) and the Meta Pixel (Meta Platforms Ireland Limited): counting the sign-ups that come from our ads, and showing our ads to people who visited us_gcl_au and _fbp, up to 90 daysConsent (Article 6(1)(a) GDPR)

Google and Meta may process this data in the United States, under the EU–US Data Privacy Framework. For the Meta Pixel, ChatPuff and Meta Platforms Ireland Limited are jointly responsible for collecting the data on our site and transmitting it to Meta (Article 26 GDPR); what Meta does with it afterwards is its own responsibility, as its privacy policy explains.

4. Where data is stored

ChatPuff runs on servers in Germany operated by Hetzner Online GmbH, and its backups are stored in Germany. Web traffic to ChatPuff passes through Cloudflare, which protects our servers and, for that purpose, handles traffic in transit at its data centers, including in the European Union; Cloudflare stores no ChatPuff data. When we use providers outside the European Economic Area (section 6), we rely on an adequacy decision or on the European Commission's standard contractual clauses, and we choose processing in the EU where the provider offers it.

5. How long we keep data

DataRetention
Conversations, attachments and the rating given6 months after resolution by default; the merchant can shorten it
Name and email a shop's customer gives in the chat windowAs long as that customer's conversations are kept; without a conversation, 24 hours after the chat window was last used
Merchant accountsUntil the organization is deleted (14 days after the request); free organizations unused for 12 months are deleted after a 30-day notice
Codes and links sent by email (finding earlier chats, verifying an order, continuing a conversation)Codes work for 15 minutes and links for 7 days; both are deleted 30 days after they expire, or earlier with their conversation
Security and audit records, including our support staff's access to conversations6 months
Technical logs, and records of ended sign-ins, password-reset links and invitations30 days; a native app's push token is deleted when its sign-in ends
Backups30 days; deleted data disappears from backups as they expire, and a restore reapplies deletions
Invoices and accounting recordsThe statutory period under Greek law
AI usage metadata (tokens, model, cost; never the text)90 days in detail, then billing summaries only
Dashboard statistics: daily counts per shop (never names, addresses or message texts), and each team member's own counts and ratings13 months; a team member's own counts are deleted when their access to the shop ends
Bug reports from the dashboard, with their screenshots1 year after the report is fixed or closed
The sign-up waiting list (email address and language)Until the address has an account, or 1 year after it was left
A shop's newsletter sign-ups from the chatA sign-up never confirmed, 7 days; an unsubscribed address, 30 days; a confirmed sign-up, as long as the shop keeps its list
Notices in the dashboard and the apps, and who read them90 days after the notice ends

When the law requires us to preserve an organization's data, for example for a legal claim or at an authority's request, we pause the deletion of that organization's data for as long as the requirement lasts (a legal hold). The hold is recorded with its reason, and deletion resumes when it ends.

6. Who receives data

We share personal data only with the processors we need to run the Service, under contracts that bind them to our instructions:

ProcessorPurposeLocation
Hetzner Online GmbH, GermanyServers, backups and the mail server that sends our emailsGermany
Cloudflare, Inc., United States (through its EU entity)DNS, protection and delivery of web traffic in transit; Turnstile on sign-in pagesGlobal network, EU data centers; certified under the EU–US Data Privacy Framework
Stripe Payments Europe, Ltd., IrelandPayments, subscriptions, VAT number checksEU, with transfers to Stripe, Inc. under standard contractual clauses
Elorus (elorus.com), GreeceIssuing receipts and invoices and transmitting them to the Greek tax authority (myDATA)Greece
Google Cloud EMEA Limited, Ireland (Vertex AI)Generating AI answers with Google's Gemini models and with Anthropic's Claude models served by Google, and indexing shop knowledge, only for shops that enable AIEU regions; Google does not use the data to train its models
Google Ireland Limited, Ireland (Google Tag Manager, Google Analytics) (only with your consent, on chatpuff.com)Measuring visits to the website (section 3)EU and United States, under the EU–US Data Privacy Framework
Apple Inc. (Apple Push Notification service) and Google LLC (Firebase Cloud Messaging)Delivering push notifications to staff; the notifications carry identifiers only, never message texts or namesUnited States, under the Data Privacy Framework

We also disclose data when the law requires it, to authorities with a valid legal basis, and we tell the merchant concerned unless the law forbids it. We never sell personal data.

7. Security

Data is encrypted in transit (TLS) and in its backups. Access to production systems is limited to named administrators with multi-factor authentication, and our administration asks for an authenticator code again after 30 minutes without activity. Our support staff can read a shop's conversations only through a read-only access that lasts at most 24 hours, with a recorded reason, which the shop's owners see in their dashboard. Each organization's data is isolated by access checks on every request. Sessions can be revoked, all administrative actions are logged, and message texts never appear in technical logs. Uploaded files are scanned for malware. Production errors are reported to our administrator by email with the error and the request reference, never with personal data. Our data processing agreement describes these measures in detail.

8. Your rights

Under the GDPR you may ask for access to your personal data, its correction or deletion, a restriction of processing, its portability, and you may object to processing based on our legitimate interests. Where processing is based on consent, you may withdraw it at any time. Write to support@chatpuff.com; we answer within one month. If you are a customer of a shop, address your request to the shop, which is the controller; we help it answer.

You may lodge a complaint with a supervisory authority, in particular the Hellenic Data Protection Authority (dpa.gr, Kifissias 1-3, 115 23 Athens), or the authority of your own country.

We do not make automated decisions with legal effects about you. AI answers in a shop's chat are suggestions from the shop, which a person can always take over.

9. Changes to this notice

We update this notice when the Service or the law changes, and we date each version. Material changes are announced to merchants by email at least 30 days ahead. Earlier versions are available on request.

10. Language

The Greek version of this notice is the authoritative text. The versions in other languages, English included, are translations: if one of them differs from the Greek version, the Greek version prevails.

11. Contact

Nikolaos Sarafoudis, 8 Nikolaou Plastira Str, 56334, Thessaloniki, Greece · support@chatpuff.com