Privacy notice

1. Who processes your data, and who answers for what

When you write to a shop's chat, your messages are the shop's business: the shop decides why and for how long to process them. In legal terms, the shop is the controller.

Numen di Rasman Francesco provides the software that runs the chat and acts as processor on the shop's behalf, under the Article 28 GDPR agreement that every shop accepts.

You will find the shop's name and contact details on the site where you opened the chat. For anything about the software, you can write to privacy@vibblin.com.

Numen di Rasman Francesco
Via Bembo, 34, 34015 Muggia (TS)
Email: privacy@vibblin.com

2. What we store when you chat

Only what is needed to run the conversation and to let the shop owner find it again.

“Pre-contractual measures at your request” means something simple: it serves to answer the request you made. It is not consent, so there is nothing to withdraw: if you do not want the shop to answer you, just do not write to it.

If the shop asks for your name, email, phone or an attachment in a form, you are the one leaving that data and it stays with the shop: the form always says what it is for.

Write only what your request needs. If you write information about your health or other sensitive data in the chat, it becomes part of the conversation: it is processed by the shop, which is the controller and decides how, and it is kept like the rest of the conversation.

3. What we do NOT do

• No cookies on the shop owner's site: the chat does not write a single one.
• No tracking across sites, no advertising profile, no selling of data.
• Your IP address does not go into the conversation data: if you leave a contact, only a fingerprint of it is kept, computed with a secret key, which serves against abuse; without the key, which stays on our servers, the address cannot be traced back. The address appears in the clear only briefly: in the counters that limit overly frequent requests (one day at most) and in the server logs (14 days).
• Your messages do not train any artificial intelligence model, neither ours nor anyone else's.

4. For how long

It depends on the plan the shop subscribes to. Once the term is over, conversations and messages are deleted automatically, every night.

The shop can also delete them earlier, whenever it wants. If the shop stops using VIBBLIN, the data is deleted at the latest 30 days after the end of its contract. Search statistics are kept 90 days; technical error records 30 days; server logs 14 days.

5. You are talking to an artificial intelligence

The assistant is an artificial intelligence system, not a person. The “AI” label next to its name and the line “Responses generated by AI” at the top of the window tell you so: no shop setting can remove them. If you ask, the assistant must confirm it.

Price estimates, where they exist, are not invented by the model: the software computes them by applying the rules and prices the shop owner wrote. They remain estimates, not binding offers.

You can ask to speak to a person at any time: just say so in the chat. The request reaches the shop, which answers you.

6. Where your data goes

To generate the replies, the text of the conversation is sent to the main language-model provider, Anthropic, and, only when that one does not respond, to the backup provider, OpenAI; each reply then goes through OpenAI's automatic check, which receives the reply and, in shops with custom instructions, also your message that the reply answers. Before it leaves, the software masks the personal data it recognises — emails, phone numbers, IBANs, card numbers, tax codes, VAT numbers, postal addresses, IP addresses — replacing them with placeholders, in every message sent to the language-model providers: the message you have just written, the earlier messages of the conversation and the reply sent to the check. Everything else, including your name and order numbers, goes as you wrote it. The real data stay on our servers: we use them to show you the reply and to collect the details you want to leave with the shop.

Anthropic processes the data in the United States under the European Union's standard contractual clauses (modules 2 and 3), which are part of its data processing agreement. For OpenAI, transfers to the United States take place under the standard contractual clauses approved by the European Commission or, where it applies, an adequacy decision of the European Commission. For countries without an adequacy decision, such as the United Arab Emirates, the standard contractual clauses alone apply.

Neither Anthropic nor OpenAI uses your messages to train their models. Anthropic deletes questions and replies within 30 days, except when it must keep them longer to enforce its usage policy or to comply with the law.

Paddle, the company that sells the subscriptions to shops, receives no visitor data.

7. What stays in your browser

The chat uses no cookies, but it does keep a few things in the browser's memory, because otherwise it would lose the thread at every click.

None of this leaves your browser on its own, and you can clear it whenever you like from your browser settings (site data).

8. Your rights

You can ask to access your data, to have it corrected, deleted, its use restricted, to receive it in a readable format and to object to the processing.

The request goes to the shop, which is the controller: its contact details are on its site. We give the shop the tools to answer — export and deletion are two buttons in its dashboard — and we assist it where needed.

You can also ask the shop to delete a single conversation: its dashboard has the button that does it, without waiting for the automatic deletion.

If you write to us, we forward the request to the shop: we cannot decide in its place.

9. How we protect the data

These are the measures that actually exist, not a list of good intentions.

• Traffic encrypted with TLS between your browser and our servers.
• Passwords stored as scrypt hashes, never in the clear; a password change closes every open session.
• Masking of recognised personal data in every message sent to the language-model providers, including the message just written and the reply sent to the automatic check (section 6).
• IP addresses kept only as a keyed fingerprint.
• Access to a shop's data granted only to that shop, checked on every request.
• Progressive lockout of failed sign-in attempts and rate limits on public endpoints.
• Backups: every day a copy of the database, kept on the server for 14 days, and every week a copy of the whole server, kept by the hosting provider separately from the server. Restoring from a copy has actually been tested.

10. Who the controller is

For the data of your account, of your sign-up and of your relationship with us, the controller is Numen di Rasman Francesco, Via Bembo, 34, 34015 Muggia (TS), VAT number 01452730326. For anything about your data, write to privacy@vibblin.com.

Two clarifications:

• for the data of your visitors the controller is you, and we are the processor: the rules are in the Data processing agreement;
• for the data needed to purchase the subscription, Paddle is also a controller, on its own account (section 14).

This data may be your own, if you are the business (a sole trader, a professional), or that of the person who signs up for the business.

11. What data we process, why and on what basis

Email, password, business name, country and language are needed to sign up, and the card on Paddle is needed to start the trial: without them, the account cannot be created. News by email is optional.

12. Signing up on the website

What we store. While you sign up we store the form data, the password only as a hash, the code we send you by email only as a fingerprint, and the keyed fingerprints of your IP address and of your browser. The IP address appears in the clear only in the counters that limit overly frequent sign-ups (one day at most), in the server logs (14 days) and in the signature with the code (below).

For how long:

• if you do not enter the code within 24 hours of the last one we sent you, the sign-up and its data are deleted;
• if you confirm but do not add the card, after 3 days we send you a reminder and 7 days after confirmation we delete everything;
• if the sign-up succeeds, it stays with the account as proof of how the contract was concluded, and goes when the account goes.

The signature. When you enter the code — during sign-up, or on the acceptance page if you are already a customer — we keep with the acceptances the email address we sent it to, when you ticked the boxes and when you entered the code, its reference (not the code), the IP address and the browser (user agent) you entered it from, the language and the versions of the documents. They serve to show that it was you who approved the clauses, as the Italian Civil Code requires, and they stay as long as your account exists (Terms, point 3.6). We keep the code itself only as a fingerprint, and delete it one week after it expires. Legal basis: contract and legitimate interest in defending our rights (Art. 6.1.b and f).

The emails. We send at most 3 sign-up emails a day to any one address. To count them we keep, for two days, a counter linked to a fingerprint of the address.

“You already have a VIBBLIN account”. If someone signs up with an address that already has an account, or a sign-up in progress, we send “You already have a VIBBLIN account” to that address instead of the confirmation. That way the account holder knows someone tried, and whoever filled in the form does not find out whether the address is ours. To do this we store nothing new, apart from the email counter; this email may also reach someone who never signed up themselves, if someone else typed their address. Legal basis: our legitimate interest, and yours, in protecting the account (Art. 6.1.f).

13. One trial per email and per site

To grant the free trial only once we keep:

• a fingerprint of the email computed with a secret key: not the email itself;
• a fingerprint of the domain of every site on which the widget appears during the trial, computed with the same key: not the domain itself;
• the date the trial started.

This data serves no other purpose. We keep it for 24 months from the start of the trial, even if you delete the account in the meantime: otherwise deleting it would be enough to get a new trial. Then we delete it. The legal basis is our legitimate interest in not having a free offer, which costs us money, used more than once (Art. 6.1.f); we have balanced it by keeping the minimum — a fingerprint instead of the email and of the domains — and for a limited time. You can object by writing to privacy@vibblin.com.

The check is automatic: if the email fingerprint matches, the sign-up offers you the subscription without a trial; if the domain has already been used by another trial, the widget on that site does not start until you activate the subscription. If you think it is a mistake, write to us and a person will look at it.

14. Payments: Paddle

Who it is. VIBBLIN subscriptions are sold by Paddle.com Market Limited, 30 Old Bailey, London EC4M 7AU, United Kingdom, our reseller (Merchant of Record). You conclude the purchase with Paddle.

What Paddle collects. In the checkout Paddle asks for your email, country, postcode (in Italy) and payment details; if you add them, your VAT number, company name and address. According to its privacy notice it also processes device and IP address data, among other things to prevent fraud.

In what role. Paddle and we process this data as independent controllers, each for its own purposes: this is written in the contract between us and Paddle. Paddle uses it to sell, collect payment, apply taxes, keep its accounts, meet its legal obligations (for example checks against international sanctions) and prevent fraud, as its privacy notice explains: paddle.com/legal/privacy. For the data Paddle processes, contact Paddle: privacy@paddle.com.

The card. We never see or store the full card number. From Paddle we take the card network and the last four digits, and these are the only card details we store, to show them to you in “Your plan”.

What we see. In Paddle's control panel, and through its services, we can see the data of your purchase: name, email, billing address, company name and VAT number if you gave them, purchases and refunds, and for the card also the expiry date and the cardholder's name. We use them only for payment support, for refunds and for accounting for the payouts we receive from Paddle; in our database we store only what the table in section 11 says. We do not use them to send you advertising without your consent.

15. VIBBLIN news by email

At sign-up there is a separate box, optional and unticked, to receive VIBBLIN news by email. If you tick it, we use your email and your dashboard language only for this, and we keep the date of your consent. You can stop whenever you like, with the link in every email or by writing to us: from then on we do not write to you any more. Withdrawing consent changes nothing in the service. The emails are sent through our email provider (section 17).

16. Internal alerts

When a new sign-up arrives, or someone tries to sign up with an address that is already ours, whoever runs VIBBLIN receives an email alert with the business name written in the form, the country and the language. When the widget of a trial appears on a site that has already had the trial, the alert gives the business name and the domain of the site. Subscription alerts also arrive by email — new shop, successful or failed payment, plan change, cancellation, suspension, closure, chargeback — with the business name, the plan, the amounts and the dates. Never the email address. On Telegram only the title of the alert arrives: it may give the plan, the amounts and the dates, never the business name, the email address or the domain.

The alerts serve to follow sign-ups and subscriptions and to spot abuse (legitimate interest, Art. 6.1.f).

17. Who we share data with

• With the providers that process it on our behalf, as processors: hosting (servers, database and backups), the email provider (service emails and news) and the language-model providers: Anthropic, the main one, and OpenAI, the backup one, which also checks the replies and the texts before they reach visitors (when the assistant replies and when it translates your texts into the other languages, they receive the business name and the texts you wrote for the assistant; if your shop has custom instructions, OpenAI's check also receives, with each reply, the visitor's message it answers). They are the same as in the list of sub-processors.
• With Paddle, an independent controller, for the purchase (section 14).
• With the authorities, when the law requires it, and with our advisers (legal, accounting), when needed, bound to confidentiality.

We do not sell data to anyone.

18. Transfers outside the European Union

• Paddle is based in the United Kingdom, which has an adequacy decision from the European Commission (Decision (EU) 2025/2574, valid until 27 December 2031). According to its privacy notice Paddle may also transfer the data to its group companies and to its providers in other countries, with standard contractual clauses.
• Anthropic, the main language-model provider (data processed in the United States): the European Union's standard contractual clauses (modules 2 and 3), in its data processing agreement. OpenAI, the backup provider (United States): standard contractual clauses or, where it applies, an adequacy decision of the European Commission.

19. For how long

What Paddle keeps is decided by Paddle, under its privacy notice.

20. Your rights

You can ask to access your data, to correct it, to delete it, to restrict its use, to receive it in a readable format and to object to processing based on legitimate interest; you can withdraw your consent to news whenever you like, without affecting what was done before.

Many things you can do yourself, from Dashboard → Privacy & GDPR: export the data and delete the account. For everything else write to privacy@vibblin.com: we reply within one month. For the data Paddle processes: privacy@paddle.com.

21. Automated decisions

We do not take decisions based solely on automated processing that have legal effects on you. The only automated checks at sign-up are the brakes against abuse and the check for a trial already used (section 13): if you think they have treated you wrongly, write to us and a person will look at it.

22. Minors

The service is not aimed at anyone under 16 and never asks for an age. If a shop reports a minor's data to us, we delete it.

23. Changes to this notice

Every version carries a number and a date, at the top of this page. If something substantial changes, the version goes up and we write to shop owners at the account email address. This notice is not accepted: it is read.

24. Complaints

If you believe your data is being mishandled, you can turn to the supervisory authority of your country. In Italy: Garante per la protezione dei dati personali (the Italian Data Protection Authority), Piazza Venezia 11, 00187 Rome — garanteprivacy.it.