aiPrivacy Policy
Effective as of 1 July 2026
This Policy explains what personal data the AI Assistant service processes, for what purposes, on what legal grounds, with whom it may be shared and how you can exercise your rights.
1. Who we are
The AI Assistant service (the “Service”, “we”) is provided by Individual Entrepreneur Volodymyr Vasylovych Teteruk (sole proprietor registered in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations of Ukraine), address: 27/2 Novopyrohivska St., apt. 28, Kyiv, 03045, Ukraine. You can contact us at volodymyr.founder@aiassistant.com.ua.
AI Assistant is a platform that provides businesses (“Clients”) with automated AI assistants. The assistant replies on behalf of the Client to messages from the Client’s end users in Instagram Direct and Facebook Messenger, helps with general information, appointments and bookings, and hands the conversation over to a human manager when needed.
2. Our role: controller and processor
Our role with regard to personal data depends on whose data it is:
- End users’ data (people who message a Client’s business on Instagram or Messenger). Here the data controller is the business Client, who determines the purposes of communicating with its customers. AI Assistant acts as a processor and processes this data solely on the Client’s instructions and in accordance with this Policy and Meta’s terms. For questions about how a specific business processes your data, please contact that business first and consult its own privacy policy.
- Account holders’ data of the Service itself (representatives of the business Client who connect their accounts to the platform). Here the controller is AI Assistant.
3. What data we process
| Category | Examples |
|---|---|
| Message content | Text as well as attachments (images, files, voice messages) that the user sends in a conversation with the business |
| User identifiers | Profile name or nickname, user identifier within a page/account (page-scoped / Instagram-scoped ID), profile photo — to the extent provided by Meta’s platforms |
| Conversation metadata | Message timestamps, conversation identifier, language, status (bot / handed over to a manager) |
| Appointment/booking data | Name, contact details, preferred date and time, service — if the user provides them for an appointment |
| Client account data | Name, email, business name, access tokens for connected Meta pages and accounts |
We do not intentionally collect special categories of data (health, religion, etc.) and ask you not to send them in the chat. We do not use users’ data for targeted advertising and do not sell or license personal data.
4. Data sources
We receive data: (a) directly from the user when they message the business; (b) from Meta’s platforms (Messenger Platform, Instagram Messaging API) via official webhooks, when the business has connected its account to the Service; (c) from the business Client itself during setup.
5. Purposes and legal bases of processing
- Providing replies and handling the conversation — so the assistant can understand the request and respond. Basis: performance of a contract / legitimate interest of the business Client in serving its customers.
- Appointments and bookings — passing data to the business’s CRM system to make an appointment. Basis: taking steps at the user’s request / performance of a contract.
- Handing the conversation over to a manager — when human involvement is required. Basis: legitimate interest / performance of a contract.
- Security, abuse prevention, compliance — event logs, spam protection. Basis: legitimate interest and legal obligation.
6. Automated processing and human involvement
Replies in the conversation are generated automatically by an AI model. However, we do not make decisions producing legal or similarly significant effects about you based solely on automated processing (Art. 22 GDPR): booking confirmations follow deterministic rules, and complex or contested matters are handed over to a human manager. You can ask to be connected to a human at any time.
7. With whom we share data
We engage a limited number of trusted providers (sub-processors) that process data on our instructions:
| Recipient | Purpose | Location |
|---|---|---|
| Meta Platforms Ireland Ltd | Message delivery via Messenger / Instagram | EU / USA |
| Contabo GmbH | Server hosting and data storage | Germany (EU) |
| AI model provider (configured individually per Client) | Processing of message text by an AI model to generate a reply (inference via API) | Depends on the provider |
| The business Client’s CRM system (chosen by the Client) | Making appointments/bookings, as chosen by the Client | Depends on the provider |
We do not use the content of your messages to train our own AI models; the AI model provider receives data only to generate a reply within the specific conversation.
We may also share with the business Client, on whose behalf the conversation is conducted, the data of its users — as it is the controller of that data. We do not share data with third parties for their own marketing purposes. The current list of sub-processors for a specific business Client is available on request via the contact details below.
8. International data transfers
Part of the processing (in particular by the AI model) may take place outside the European Economic Area and Ukraine. In such cases we apply appropriate safeguards in accordance with applicable law (such as standard contractual clauses or other mechanisms provided by law). We minimise the amount of data passed to the AI model to what is necessary to generate a reply.
9. Retention period
We keep conversation data only for as long as necessary to provide the Service to the business Client. After our cooperation with a Client ends, its conversation data is deleted or anonymised within 90 days. Technical security logs are kept for no longer than 12 months. Data is deleted earlier upon request of the user or the business Client (see the “Data Deletion” section). Where the law requires us to keep certain data longer (for example, for accounting), we retain it for the legally required period and do not use it for other purposes.
10. Your rights
Depending on applicable law (including the GDPR and the Law of Ukraine “On Personal Data Protection”), you have the right to: access your data and information about the sources it was collected from; rectification; erasure; restriction of processing; objection to processing; and data portability. You also have the right to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights, with an EU supervisory authority in your place of residence, or with a court. Since the business Client is the controller of end users’ data, we may forward your request to it. To exercise your rights, write to volodymyr.founder@aiassistant.com.ua.
11. Data deletion
You may request deletion of your personal data at any time. The procedure is described on a separate page: Data Deletion.
12. Security
We apply organisational and technical safeguards: encryption of secrets and access tokens, least-privilege access controls, isolation of different business Clients’ data, logging of significant actions.
13. Cookies and tracking
This website sets no cookies and uses no third-party analytics or trackers; fonts and other resources are served from our own server.
14. Children
The Service is not intended for persons under 13 years of age, or under the age at which local law permits the use of the relevant Meta platforms. We do not knowingly collect data of such persons.
15. Compliance with Meta platform policies
When processing data from Messenger and Instagram, we comply with Meta’s Platform Terms and Developer Policies. We process Meta platform data solely on behalf of and at the direction of the relevant business Client — only to provide and improve the Service, never for our own purposes or the purposes of other clients — and do not transfer it for incompatible purposes.
16. Changes to this Policy
We may update this Policy. The current version is always available on this page with its effective date.
17. Contact
Individual Entrepreneur Volodymyr Vasylovych Teteruk
27/2 Novopyrohivska St., apt. 28, Kyiv, 03045, Ukraine
E-mail: volodymyr.founder@aiassistant.com.ua