Legal

Privacy Policy

Last updated: [EFFECTIVE DATE]

Introduction

In the following, we provide information about the collection of personal data when using

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1. General information

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is [COMPANY], [ADDRESS], email: hello@allback.ai. We are legally represented by [REPRESENTATIVES].

Our data protection officer can be reached via [DPO].

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a customer uses AllBack to send forms. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website, or to protect our service against abuse.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. [SUPERVISORY AUTHORITY LINK]

If you answered a form that one of our customers sent you, the customer decides about your answers. Please send requests about your answers to the sender of the form first. You can also write to us, and we will forward your request to the sender (see section 4).

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Automated checks help us find abuse, such as phishing forms (see section 4.3). A person reviews a decision before we close an account for abuse, unless the risk to the people who answer requires immediate action. Should we use fully automated procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us.

We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Newsletter and service emails

We reserve the right to inform customers who have already used services from us from time to time by e-mail about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

We send service emails that are necessary to provide AllBack, such as sign-in codes, confirmations, and messages about your account (Art. 6 para. 1 s. 1 lit. b GDPR).

We send emails with the tool

  • Resend of the provider Resend, Inc. [RESEND ADDRESS] (privacy policy: https://resend.com/legal/privacy-policy). The provider processes contact data, content, and meta/communication data in the process in the USA.

3. Data processing on our website

3.1. Notice for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.

This storage and access is based on the following provisions:

  • Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to keep a user signed in, or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz, "TDDDG").
  • Otherwise, this storage or access takes place on the basis of the website visitor's consent (Section 25 para. 1 TDDDG).

The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

  • IP address
  • Date and time of the request
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after [LOG RETENTION DAYS] days.

To limit abuse, we store a one-way hash of the IP address when someone creates a form without an account. We cannot read the IP address from this hash. We delete it together with the form.

3.3. Web hosting and provision of the website

Our website, our dashboard, our connector, and the forms are hosted by Cloudflare. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data. Our database and the uploaded files are stored in [DATA REGION]. Cloudflare delivers the website through its global network. Further information can be found in the provider's privacy policy at https://www.cloudflare.com/privacypolicy/.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

3.4. Cookies

We only use cookies that are necessary for the service. We do not use cookies for analytics or advertising.

  • ab_session: keeps you signed in to the dashboard. It is deleted after 30 days or when you sign out.
  • ab_verified: remembers for 30 days that a person confirmed their email with a code before a protected form opened.
  • ab_open_…: remembers for 30 days which answer belongs to this browser when a person answers through an open link, so they can come back to their draft.
  • ab_signed_in: tells our website that you are signed in, so it can show "Open the app" instead of "Get started". It holds only the value 1, and no name, email, or session data. It is valid on allback.ai and its subdomains, and it is deleted after 30 days or when you sign out.
  • ab_layout and ab_flayout: remember for 1 year the view you picked for your requests and your forms in the dashboard (board, list, or cards).
  • ab_theme: remembers for 1 year the theme you picked in the dashboard (light or dark). It holds only that word. When you pick "System", we delete it.

3.5. Customer account

Site visitors can open a customer account on our website. We do not use passwords. To sign in, you enter your email address, and we send you a 6-digit code. We process the email address, the codes (stored only as a hash), and the time of sign-in to provide the account (Art. 6 para. 1 s. 1 lit. b GDPR).

You can build and test a form before you have an account ("guest form"). To send it, you confirm your email address with a code, and the form moves to your account. We delete guest forms that nobody claims after 30 days.

3.6. Connecting an AI app

You can connect AllBack to an AI app, such as Claude, ChatGPT, or Gemini, or use our CLI. When you sign in through the AI app, the app receives a token that lets it use AllBack for you. We store which app is connected and the token, so the app can act for you (Art. 6 para. 1 s. 1 lit. b GDPR).

What you type in the AI app, and what the AI app does with the answers it receives from AllBack, is processed by the provider of the AI app under its own terms and privacy policy. We do not control this processing.

3.7. Applications for free access

Schools, nonprofits, and communities can apply for free access on our website. We process the data in the application (e.g. name, email address, organization, and its purpose) to review the application (Art. 6 para. 1 s. 1 lit. b GDPR). We delete the data of rejected applications after [APPLICATION RETENTION].

3.8. Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR). We never see or store full card numbers.

These payment processors are:

  • Stripe Payments Europe, Ltd., Ireland

3.9. Third parties

3.9.1. Google Fonts

Our website uses fonts from Google Fonts. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When a page loads, the browser connects to the servers of Google, which receive the IP address of the site visitor. It is our legitimate interest to show our website in a uniform design, so the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR. Further information is available in the provider's privacy policy at https://policies.google.com/privacy.

4. Our Platform

4.1. Data that our customers collect

For Customer or end-user data that we host and process on our Platform only on instructions from our Customer, we are the data processor. This includes the forms, the lists of people that a customer adds (e.g. names, email addresses, and prefilled values), the answers, the uploaded files and signatures, and the events that show the customer who opened, started, and finished a form.

The customer is the controller for this data. The customer decides what to ask, whom to ask, and how long to keep the answers. Our data processing agreement with our customers governs this processing.

4.2. People who answer a form

If a customer sends you a form through AllBack, we send you emails for the customer: the invitation and, if you do not answer, reminders. Each email says who sent the form. You can stop the reminders with the link in each email, and you can report a form that looks wrong. Three reports close a form at once.

Some forms ask you to confirm your email address with a code before the form opens. Some forms use an open link that anyone can fill. In this case, a cookie connects your browser to your draft (see section 3.4).

Please send questions about your answers to the sender of the form. You can also write to hello@allback.ai, and we will help or forward your request.

4.3. Security and abuse prevention

For certain processing activities carried out on our Platform, such as security monitoring and the prevention of abuse, we are the data controller. Automated checks, including a review by an AI model, look at new forms, open links, and applications for free access. They look for phishing, requests for passwords or payment details, and spam. Our legal basis is our legitimate interest in protecting the people who answer forms and our service (Art. 6 para. 1 s. 1 lit. f GDPR).

We use the following service providers for this, who process data only on our documented instructions:

  • [AI PROVIDER], for the AI review of new forms. [AI PROVIDER DETAILS]

4.4. Improvement of the Platform

For processing of personal data we deem necessary to improve and develop the Platform ("Improvement Data"), such as counts of how the Platform is used, we are the data controller. Our legal basis for processing Improvement Data is our legitimate interest. We deem the Improvement Data as necessary to achieve our purpose of improving our Platform and Service offering. We do not use the content of forms or answers to train AI models.

5. How We Protect Your Data

We are committed to protecting the privacy and security of your personal data. Our security practices are designed to protect your information from unauthorized access, alteration, disclosure, or destruction.

  • Encryption: All data transmitted between your device and our servers is encrypted using Transport Layer Security protocol. Our hosting provider encrypts stored data at rest.
  • Access Control: Access to user data is strictly limited to authorized personnel who require it to perform their duties. We use multi-factor authentication for the systems that hold user data. We also adhere to the principle of least privilege.
  • Private files: Uploaded files are private. Links to files expire. Download links in exports expire after 7 days.
  • Data Minimization: We only collect and retain data that is necessary for the functionality of our application. Demo forms on our website reset their answers and delete their files after 30 minutes.
  • Third-Party Processors: We do not sell or rent your personal data to anyone. We use trusted third-party services (e.g. for hosting and email) to operate our application.
  • Data Deletion: If you stop using AllBack, write to hello@allback.ai, and we will delete your account and the data you have provided to us.

Although we work to protect the security of your account and any data that we hold, no method of transmitting data over the internet is ever fully secure or error-free and we do not guarantee the security of your data. You should also take steps to protect your data, including protecting access to your email account and your devices.

6. Children

AllBack is not directed to children. Customers such as schools may use AllBack to ask parents or guardians for information about their children, for example a permission slip. In this case, the school is the controller for this data (see section 4.1).

7. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

8. Questions and Comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.