Privacy Policy

Last updated: [date]

This Privacy Policy explains how [Company legal name] ("tehil.io", "we", "us") collects, uses and protects personal data when you visit tehil.io, use our platform as an advertiser or publisher, or interact with an AI chat that uses our technology.

1. Who is responsible for your data

[Company legal name], [legal form], registered under number [number], with its registered office at [address]. Contact: privacy@tehil.io.

Our role depends on the context:

Website visitors and platform account holders: we are the data controller.
End users of a publisher's AI chat using our SDK: the publisher is the controller of its chat. We process conversation data to select and serve sponsored answers [as a processor on the publisher's behalf / as an independent controller for ad selection: to confirm with counsel]. Our obligations are set out in our Data Processing Agreement with each publisher.
End users of a custom chat built and run by tehil.io: [role to confirm with counsel, typically joint controllers with the publisher].

2. Data we collect

Website visitors: IP address, browser and device information, pages visited, referral source, and information you submit in forms (name, email, company, website, traffic estimates).

Advertisers and publishers (account holders): contact and company details, login credentials, billing and payout information, campaign settings and creatives, SDK configuration, and usage of the platform.

End users of chats using our technology: the content of the conversation needed to understand context (messages and AI responses), approximate location derived from IP, language, device type, timestamps, and interactions with sponsored answers (impressions, clicks, conversions).

We do not knowingly process special categories of data (health, religion, political opinions, etc.) for ad selection. Conversations detected as sensitive are excluded from sponsored placements.

3. How we use data

Purpose	Data	Legal basis (GDPR)
Selecting a relevant sponsored answer in real time	Conversation context, location, language, device	[Legitimate interest / publisher's legal basis: to confirm]
Measuring impressions, clicks and conversions	Interaction data, pseudonymous identifiers	Legitimate interest; consent where required
Billing advertisers and paying publishers	Account, campaign and payout data	Performance of contract
Preventing fraud and abuse	Technical and interaction data	Legitimate interest
Operating and improving the platform	Usage data, aggregated statistics	Legitimate interest
Responding to requests and sending service emails	Contact data	Contract / legitimate interest
Marketing emails	Contact data	Consent (unsubscribe anytime)

What we do not do: we do not sell personal data, we do not build cross-site profiles of end users, and sponsored content never alters the AI's own answer.

4. Retention

Conversation content used for ad selection: [X hours/days], then deleted or irreversibly anonymized.
Interaction and reporting data: [X months], then aggregated.
Account and billing data: for the duration of the contract, then as required by accounting and tax law ([X years]).
Website analytics: [X months].

5. Sharing

We share data only with:

Service providers acting on our instructions: hosting, analytics, payments, email, AI model providers. Current list: [link to sub-processor list].
Advertisers: aggregated campaign reports only. Advertisers never receive conversation content or identifiable end-user data.
Publishers: reporting on placements and earnings in their own chat.
Advertising channels such as ChatGPT Ads: campaign settings and creatives submitted by advertisers, to run their campaigns on those channels. Publisher conversation data is not shared with these channels.
Authorities, when required by law.

6. International transfers

Some providers may process data outside the European Economic Area. Where this happens, we rely on adequacy decisions (including the EU adequacy decision for Israel) or Standard Contractual Clauses.

7. Security

Encryption in transit and at rest, access controls, logging, and pseudonymization of data used for ad selection where possible.

8. Your rights

Under the GDPR and applicable laws, you can request access, rectification, deletion, restriction, portability, and object to processing based on legitimate interest. You can withdraw consent at any time. Write to privacy@tehil.io. If you used a publisher's chat, you can also contact that publisher directly; we will support them in handling your request.

You may lodge a complaint with your local data protection authority (in France, the CNIL).

9. Cookies

Our website uses strictly necessary cookies and, with your consent, analytics cookies. You can change your choices at any time via [cookie settings link]. Our SDK [does / does not] set cookies in publisher chats: [to confirm].

10. Children

Our services are not directed at children under 16. Publishers must not use our SDK in chats directed primarily at children.

11. Changes

We may update this policy. Material changes will be announced on this page and, for account holders, by email.

12. Contact

privacy@tehil.io · [postal address] · [DPO or EU representative, if applicable]