Privacy Policy

Gammatica

Gammatica AI-Powered Management Platform

Version 2.15 · Effective 14 November 2026 · Replaces v2.14 of 11 November 2026

What changed in version 2.15

A new part of Section 2.2, “Signing in with a passkey”, describes what we store about a passkey, what we never receive (biometric data and the private part of the key), what the User’s password manager saves with the key, and how long we keep the data. Section 2.12 now covers passkeys in the mobile app, and Section 6.5 states that passkeys are also deleted when the account is deleted.
Sign-in with an Apple account is also available on the web interface; Section 2.2 and the Apple row in Section 3 now reflect this.

What changed in version 2.14

In Section 5, the paragraph “Pages published by Users” now describes exactly what Gammatica measures on the pages Users publish: page views, clicks on the configured conversion button and the new Heatmap, without cookies, in aggregate, on the User's behalf. A new paragraph sets out what data the Heatmap sends, what it does not record and how long we keep it.

What changed in version 2.13

Section 2.12 gives a more precise description of the mobile app: which device data we record, how long we keep the push token, what switching off notifications covers, what the phone stores and what stays on it after sign-out, and what the app uses the camera and photos for. A new point covers app software updates.
Sections 3 and 4 add 650 Industries, Inc. (Expo) as a recipient, for delivering software updates. The Apple and Google LLC rows now include their roles in the mobile app.
Section 6.5 names the public account deletion page, which works without signing in, and lists what is deleted and what is kept when an account is deleted.
Section 2.2 adds sign-in with an Apple account and the minimum age of 18.

What changed in version 2.12

New section 2.12 covers the Gammatica mobile app (iOS and Android): sign-up with email, Apple or Google, device data, push notifications, data stored on the phone and deleted on sign-out, and camera, photo, microphone and speech recognition access. The app contains no analytics, advertising or tracking tools.
Sections 3 and 4 add Apple as a recipient (push notification delivery on iOS). Section 6.5 describes how to delete your account in the mobile app and on the web.

What changed in version 2.11

Section 2.11 (the AI machine) states in one sentence that saved login details and sessions are stored encrypted, how long they are kept and how they can be deleted; third parties' data appearing on the web pages the machine opens is added to the data processed on the User's behalf.

What changed in version 2.10

The Google Ads row in section 2.5 is updated: the connection is no longer read-only. At the User's request and with their prior approval, Gammatica creates, pauses and modifies campaigns, the account check applies fixes, and won deals can be sent back as offline conversions.
New rows in section 2.5: Google Tag Manager, Google Analytics (GA4), Google Business Profile, and Google Search Console and Site Verification — each stating the data processed, the purpose, encrypted token storage and deletion.
Section 5.1 lists the new Google OAuth scopes; the Google LLC row in section 3 is updated accordingly. The Limited Use disclosure in section 5.1.2 applies to them as well.

What changed in version 2.9

Section 3 adds a new processor, Amazon Web Services (Amazon SES): newsletters and campaign emails are now delivered through it, within the EU (Stockholm, eu-north-1). The Bird row changes accordingly: SMS and WhatsApp messages are still delivered by Bird.
Section 4 lists Amazon Web Services among the processors that store data within the EEA.

What changed in version 2.8

A new Section 2.11 describes the AI machine: the cloud browser in which the AI agent works on websites at the User's request — the data processed, the roles, who has access, retention periods and the safeguards.
The E2B row in Section 3 now also covers running the AI machine.

What changed in version 2.7

Section 2.2 describes how we protect the free allowance: when no starter credit is given (a second account opened from the same IP address within one hour, a disposable email address) and when no free video is given. Section 2.6 lists this as an automated decision, with the option of human review.
New section 2.9 describes the daily quality review of AI conversations: the automatic, redacted review of the previous day's conversations and what we keep from it.
New section 2.10 describes the new data on the booking page: additional guests, attendance responses and deposits, which are collected by the User's own Stripe account.
Section 2.5 gets new rows: own mailbox (IMAP/SMTP) and mailbox visibility, and MyGLS parcel labels. Shopify can now be connected, and the Google Ads row describes the read-only connection.
Section 2.4 now covers transcripts of attached audio files and AI animation with voice-over.
Sections 3 and 4 add two processors: Cloudflare (traffic routing and protection) and E2B (isolated runtime for data analysis and rendering). Smartsupp is removed because we no longer use it. The Bird row now covers WhatsApp messages and incoming email. Section 3.1 adds Black Forest Labs, ElevenLabs and Microsoft to the model providers, as well as the built-in help assistant's live voice call (OpenAI).
The cookie table in section 5 gets a new row: the gm_src cookie records where the visitor came from so that the application sees this source at sign-up; without consent, the source travels only on links pointing to the application.
Section 5 now shows the cookies and measurement of the gammatica.com website and of the application separately, and states that Gammatica's tracking code does not run on pages published by Users.

What changed in version 2.6

A new subsection in Section 2.2 describes security logging: the IP address and browser identifier recorded at registration and at login, the purpose, the legal basis (legitimate interest), who has access and how long the entries are kept.

What changed in version 2.5

Section 2.5 gains four new rows: webshop integrations (UNAS, WooCommerce, Shoprenter), data migration from other systems (MiniCRM, Asana, Trello), partner applications (OAuth connection) and Gammatica's own MCP server, through which the User connects their own AI client (for example Claude or ChatGPT) to their workspace.
Connecting a Meta Ads or Google Ads account is currently in preparation and not available; the two rows record this. We will update this notice before the connection becomes available.
A new Section 2.8 describes the webshop storefront built in Gammatica: buyers' data, payment through the User's own Stripe account, and the roles.
Section 3.1 lists the model providers actually in use, including the new video, music and speech models (ByteDance, Kuaishou, Google) and the transcription of audio recordings (OpenAI).
Section 3 states that partner applications and AI clients connected by the User are not Gammatica's processors but recipients chosen by the User.
The paragraph on keys and tokens covers the new integrations and states exactly what happens on disconnection; for the Dropbox connection we recommend that the User also revoke the permission in Dropbox. The Google and Meta rows of Section 3 and the table of automated actions record the current status of ad accounts.
Section 2.7 now also covers uploaded video (reference video, video to video) and the own voice feature (voice clone); Fish Audio, which performs the voice cloning, has been added to the model providers in Section 3.1. The MCP row describes the sign-in (OAuth) and what the client may create.

What changed in version 2.4

Section 2.5 gains six rows for services the User can connect: Dropbox, the User's own Stripe account, Számlázz.hu, Billingo, and the Meta Ads and Google Ads ad accounts. Each row states which way the data moves, what we store from it, and what we do not.
The same section describes how we keep the keys and tokens the User provides, what happens to them on disconnection, and sets out the roles: for data coming from the User's own accounts, the User is the controller and Gammatica is the processor.
Section 2.3 clarifies what we store from the payment provider (identifiers, card brand and last four digits) and that full card data never reaches us.
Section 2.6 gains a row on actions the AI performs in connected accounts and the approval rules that apply to them.
Sections 3 and 4 add rows for Dropbox, Számlázz.hu (KBOSS.hu Kft.) and Meta Platforms; section 3.1 lists the model providers actually reached through OpenRouter.

What changed in version 2.3

Section 2.5 gains a row for the Meta (Facebook) Lead Ads integration: what data arrives from lead forms on connected Facebook and Instagram Pages, how it arrives, and what we do — and do not do — with it.
The same section now states the roles explicitly: for leads received through Meta Lead Ads, the customer operating the workspace is the data controller and Gammatica is the data processor. The leads come from the customer’s own advertising, not from Gammatica’s.
Section 6.5 now describes how to request deletion in practice: where to write, and the deadline we work to.

What changed in version 2.2

Section 2.6 (Article 22 GDPR) gains a row for Full AI Sales: in that mode the agent can correspond with an enquirer in the User's name without human approval. The previous text promised approval for every AI email, which did not hold in that mode.
New section 2.7 describes the processing behind portrait avatars, AI advertising images and AI video: what you upload, what happens to it, how long we keep it, and why this is not biometric processing.
We state that the system does not currently mark generated image, audio and video content, so disclosing its artificial origin on publication is the User’s responsibility (Article 50 of the EU AI Act).

What changed in version 2.1

Section 5.1 now lists the exact Google OAuth scopes we request. We no longer request Google Drive access, and calendar access is limited to reading your events plus creating and deleting the bookings made on your own booking page.
New Section 5.2 describes the AI Meeting Notetaker: what it records, where the data goes, and how to turn it off.
New sub-processors added to Sections 3 and 4: Recall.ai, ActiveCampaign (Postmark), Bird (MessageBird) and Zapier.
Our contact address is now [email protected] throughout.

This document provides information about the processing of personal data related to the Gammatica software (“Gammatica” or “Software”) owned and operated by Gammatica Korlátolt Felelősségű Társaság as the data controller (“Gammatica Kft.” or “Controller”).

The personal data of customers using the Software (“Data Subject” or “User”) is processed by the Controller in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Hungarian data protection legislation (Act CXII of 2011).

The Controller reserves the right to unilaterally amend this document at any time. The amended Privacy Policy shall be effective as of the date of its publication.

1. Data Controller

Company	Gammatica Kft.
Registered office	1123 Budapest, Nagyenyed utca 5., basement level, Hungary
Postal address	1123 Budapest, Nagyenyed utca 5., basement level, Hungary
Company reg. no.	01-09-434270
Court of registration	Budapest-Capital Regional Court
Tax number	32628186-2-43
EU VAT number	HU32628186
Represented by	Viktor Dániel Várhegyi, Managing Director
Email	[email protected] (updated 2.1)

2. Data Processing During the Use of the Software

2.1. Contact by Email

Purpose	To communicate with the User and reply to information sent by email.
Legal basis	The User’s prior, informed and voluntary consent (Article 6(1)(a) GDPR).
Data processed	Email address, other personal data provided by the User (typically name).
Retention	3 months from the date of the last communication.
Access	Employees or agents responsible for contact and enquiries.

2.2. Registration and User Account Management

By clicking “Registration”, the User declares that they have read the Terms of Service and this Privacy Policy, understand their contents, and accept the terms of data processing.

Purpose	Registration, granting access, and sending reports.
Legal basis	Performance of a contract (Article 6(1)(b) GDPR).
Registration data	First name, last name, email address.
Account data	First name, last name, password, email, language. Optionally: position, profile picture.
Retention	5 years after the termination of the contract.

After registration, Users can sign in with email and password, a Google or Apple account, or a passkey. With Google or Apple sign-in, Google or Apple passes on the name and email address, with the User’s approval; with Apple sign-in, the email address may be a private relay address. Organisation heads can invite team members by email.

The Software is intended for business use and is not directed at persons under 18, and we do not knowingly create accounts for them. If we learn that an account was created by a person under 18, we will delete the account.

Users may upload various content (client data, comments, ratings, calendar links). Gammatica provides the platform and data security but excludes responsibility for user-uploaded content.

Signing in with a passkey (new in 2.15)

On the web interface and in the mobile app, the User can create a passkey in Settings and use it to sign in without a password. A passkey is a key pair: its private part stays on the User’s device or in their password manager and never reaches us; on our servers we store only the public part, which we use to check the device’s signature at sign-in. Before creating or deleting a passkey, the User must confirm their identity again (with their password, an existing passkey or, for accounts without a password, a code sent by email). From the fifth sign-in onwards, the Software may offer to create a passkey; after “Later” it asks once more 30 days later, and never again after a second “Later” or after “Don’t ask again”.

What we store. The key’s identifier and public part, the signature counter, the key’s transport methods, the authenticator type identifier if the device provides it (we use it to show the name of the password manager, for example iCloud Keychain or Google Password Manager), whether the key is synced, the key’s name (set by the User or, by default, the name of the password manager or of the browser and operating system), and when it was created and last used. For the offer: when it may next appear, how many times the User chose “Later”, and whether they asked not to be asked again.
What we never receive. Fingerprints, face images or other biometric data, or the device PIN or screen lock: verification happens on the device. We only receive a signal of whether the device verified the User.
The password manager. The passkey is stored by the password manager the User chooses (for example iCloud Keychain, Google Password Manager or another password manager), which may sync it across the User’s devices under its own terms. So that it can offer the passkey at sign-in, the device saves the account’s email address, the User’s name and an internal account identifier with the key. Gammatica does not send any data from its servers to Apple, Google or any other password manager provider for this purpose.
Logging. We record in the security log (see below) when a passkey is created, renamed or deleted, successful and failed passkey sign-ins, when the offer is shown, accepted or declined, and when an email code for re-confirming identity is sent and checked. For sign-ins, we also record the browser or app identifier (User-Agent); for sign-ins from the mobile app, also the device identifier, platform and app version.

Purpose	Signing in without a password; protecting the User Account.
Legal basis	Performance of a contract (Article 6(1)(b) GDPR). Logging is covered by the legal basis of security logging (legitimate interest, see below).
Data processed	The data listed under “What we store” above.
Retention	Until the User deletes the passkey in Settings, and at the latest until the account is deleted. On deletion, the passkey’s data stored on our servers is erased immediately and permanently; the security log keeps only the fact of the deletion, the key’s name and the number of remaining keys, without any key material, for the period set out for security logging. We cannot delete the passkey stored on the User’s device or in their password manager; the User has to remove it there. The User’s response to the offer: until the account is deleted.

Security logging

At registration and at login we record the IP address of the request and the browser or mobile app identifier (the User-Agent string describing the browser or app and the operating system) in order to detect abuse (for example mass account creation) and to protect the account. We store these only in an append-only security log – the application cannot alter the entries – and only the platform operator has access to them; other users of the workspace cannot see them.

If an unusually high number of registrations arrives from one IP address within a short time, the operator receives an alert showing the address and the partially masked email addresses of the accounts concerned. This is not an automated decision: it does not block registration, and a person decides on any further step. In our analytics tools (Section 5), recording of IP addresses remains switched off.

Purpose	Detecting abuse (for example mass account creation); protecting the User Account and the platform.
Legal basis	Legitimate interest (Article 6(1)(f) GDPR): network and information security (Recital 49 GDPR). The User may object (Section 6.4).
Data processed	IP address, browser or mobile app identifier (User-Agent), the time and method of registration or login (email and password, Google or Apple account, or passkey).
Access	The platform operator only.
Retention	IP address and browser identifier: 6 months from recording, after which the operator removes them from the log entry. The time and method of registration and login – without the IP address or browser identifier – are kept with the account data, for 5 years after the termination of the contract. Alerts about many registrations: until the investigation is closed.

Protecting the free allowance (new in 2.7)

The starter AI credit and the free video are there so that the Service can be tried out. To stop them from being exploited at scale, we check the following at sign-up and when a video is created:

IP address. If a second account is created from the same IP address within one hour, the new workspace does not receive the starter credit or the credit gift given on the second day. Sign-up still goes ahead, and the introductory offer remains available.
Disposable email address. We compare the domain of the email address against a list of known disposable email providers. For an unknown domain, we look at its public DNS records and its website and, if needed, the domain name — without the part of the address before the @ — is also assessed by an AI model via OpenRouter (section 3.1). For a disposable domain, no starter credit is given; sign-up still goes ahead.
Free video. Until the workspace has subscribed, one free video of up to 5 seconds can be created. If the request names a video model or provider, or shows several signs of automated, bulk production, the free video is not given; to decide this, the text of the request is checked automatically. If the video is not completed because of a technical error, the free allowance is restored.

Purpose of processing	Preventing bulk exploitation of the free allowance.
Legal basis	Legitimate interest (Article 6(1)(f) GDPR): protecting the Service and the trial offer against abuse. The User may object (section 6.4).
Data processed	IP address, the domain of the email address, the text of the video request.
Retention period	For the IP address, the security logging rule above applies. The decision and its reason (with the email domain partly masked) are recorded in the workspace's audit log and kept for as long as the account data.

2.3. Billing

Purpose	Billing for services used.
Legal basis	Legal obligation (Article 6(1)(c) GDPR; Act C of 2000 on Accounting; Act CL of 2017 on Taxation).
Data processed	Name/company name, billing address, tax number, bank account number (if applicable). The customer and payment-method identifiers created at the payment provider (Stripe), the card brand and the last four digits of the card number. The full card details are entered by the User directly with Stripe; they never reach us and we do not store them. (updated in 2.4)
Retention	8 years after the relevant financial year.

2.4. Artificial Intelligence (AI) Features

Gammatica uses AI features to enhance the user experience:

AI-powered chatbot (lead qualification, customer support)
Automated text generation and content suggestions
AI-assisted CRM features (lead scoring, notifications, workflow automation)
Summary and report generation
AI-powered email reply (analysing incoming emails and generating reply suggestions)
AI Meeting Notetaker — transcription and summary of video meetings, described in detail in Section 5.2 (new in 2.1)
Time-stamped transcripts of attached audio files, and AI animation and video with voice-over (new in 2.7)

Purpose	Operating AI features to provide intelligent responses, suggestions, and automations based on User-provided data.
Legal basis	Performance of a contract (Article 6(1)(b) GDPR) — AI features are integral to the Software; and legitimate interest (Article 6(1)(f) GDPR) for service quality improvement.
Data processed	Text data entered into chat, CRM, and other fields; client data (name, email, phone, company); incoming and outgoing email content (when using AI email reply); behavioural data (interactions, clicks); uploaded document content insofar as processed by AI.
Retention	OpenRouter is configured with prompt/response logging disabled, so it does not retain prompt or response content, and requests are not routed to providers that use the data to train AI models. AI model providers may process the data only to deliver the requested feature and may retain it transiently under their own terms (for example to prevent abuse), but do not use it to train generalised AI/ML models. AI-generated content stored in the CRM is retained until the User’s account is deleted.

Important notice: When using AI features, personal data may be transmitted via OpenRouter, Inc. to third-party language model providers (see Sections 3 and 4). When using AI email reply, email content (including sender name, address, and message body) may be transmitted to the AI provider. Please do not enter special categories of personal data (health, racial, political, sexual orientation, etc.) when using AI features.

2.7. Portrait avatars, own voice, AI-generated images and video (updated in 2.5)

The Software lets the User upload a photograph or a video and have an AI avatar (a character sheet in several views), an advertising image or a short video generated from it; an uploaded video may serve as a model (reference video) or as footage to be transformed (video to video). Content produced this way is synthetic: it was created by artificial intelligence and is not a real recording.

Purpose of processing	Producing the image, avatar and video content requested by the User.
Legal basis	Performance of a contract (Article 6(1)(b) GDPR). Where the uploaded image or video shows a natural person other than the User, obtaining that person's consent is the User's responsibility (Article 6(1)(a) GDPR).
Data processed	The uploaded photograph or video, the images and videos generated from them, and the text instruction given for the generation.
Retention	Uploaded and generated files are kept until deleted by the User, or failing that until the User Account is deleted.

We do not perform biometric identification. The uploaded portrait is used solely to produce the requested content: we do not derive a biometric template from it, and we do not use it for facial recognition, identification or linking individuals. Processing of the special category of data under Article 9 GDPR therefore does not take place.

Generation follows the route described in section 2.4: the image and the instruction reach the model provider through OpenRouter, Inc.

Transparency (Article 50 of the EU Artificial Intelligence Act). The Service does not currently apply a machine-readable marking or a visible watermark to the image, audio and video content it generates. Where the User publishes such content — in particular where it depicts a real person or event — disclosing its artificial origin is therefore solely the User’s responsibility, and that obligation rests with them. We recommend labelling published content as generated with artificial intelligence.

Own voice (voice clone). (new in 2.5) The User may record a voice sample of 10–90 seconds in which they read out a fixed text; that text is itself the declaration of consent. We store the sample, its transcript and the time of consent in the workspace. An own voice can be used only by the user who recorded it — at most three per user. For narration, the sample and the transcript are passed through OpenRouter, Inc. to the model provider Fish Audio, which speaks the requested text in the User's voice. Legal basis: the User's consent (Article 6(1)(a) GDPR), which the User can withdraw at any time by deleting the own voice — from then on the voice cannot be used. The retention rule above applies to the sample file; the User may also request its permanent deletion at [email protected]. We do not create a biometric template from the voice sample and do not use it for identification.

2.5. Third-Party Integrations

Gammatica integrates with the following third-party services, activated only with the User’s explicit permission:

Integration	Purpose	Data processed
Gmail (Google)	Sending, receiving, and managing emails within Gammatica; AI-powered email reply generation	Email address, subject and body, sender/recipient data, attachment metadata
Google Calendar	Reading calendar events to display upcoming meetings, prevent double-booking on the public booking page, and schedule the AI Meeting Notetaker; creating and deleting the events generated by your public booking page. No other events are modified or deleted. (updated 2.1)	Event name, date/time, attendee emails, location, description
Microsoft Outlook (email & calendar)	Email and calendar synchronisation with Gammatica; AI-powered email reply generation	Email address, subject and body, calendar event data, attendees
Make.com (Celonis)	Automation workflows: cross-system data synchronisation, trigger-based actions	All data involved in the workflow (CRM data, email data, calendar data — depending on the scenario configured)
Zapier	Automation workflows connecting Gammatica to other applications the User chooses (new in 2.1)	All data involved in the Zap (CRM data, contact, deal, task and booking data — depending on the Zap configured)
Meta (Facebook) Lead Ads	Reading lead form submissions from the Facebook and Instagram Pages the User connects. The data is retrieved through the Meta Marketing API using webhooks and written into the User’s workspace as a contact and a pipeline card. We do not use this data for advertising, profiling, or any purpose other than delivering it to the User’s workspace, and we never share it with other customers. (new in 2.3)	The contact details the person entered (name, email address, phone number) and their answers to the lead form questions, together with the form, page and campaign identifiers
Dropbox (new in 2.4)	Searching and listing the files stored in the User's Dropbox account and reading the content of smaller text files so that the AI can answer the User's request from them. The connection is read-only: Gammatica does not upload to Dropbox and does not modify, delete or share anything there. We keep no copy of the files on our own storage; the text excerpt read may be passed to the AI provider as part of the given AI request (section 3.1). A separate switch lets the User decide whether the AI may read from the files.	The account's email address; file names, paths, sizes and modification times; a temporary download link valid for a few hours; an excerpt of at most a few thousand characters from the text file read
Stripe (the User's own account) (new in 2.4)	Connecting the User's own Stripe account with a restricted API key the User provides: revenue and balance summaries, an overview of open invoices, and the creation of payment links and checkout pages on the User's instruction. This connection is independent of Gammatica billing its own fees through Stripe (section 2.3). We do not store the transaction and customer data retrieved from Stripe: it is processed temporarily to serve the request, and the summary may be passed to the AI provider (section 3.1). We keep only the URLs of the payment links created and the User's settings.	Payment data of the User's customers: amount, currency, status, billing email address, the name and email address entered on the checkout page; the amounts of open invoices; the name and currency of the Stripe account
Számlázz.hu (KBOSS.hu Kft.) (new in 2.4)	Issuing invoices and proforma invoices in the User's own Számlázz.hu account with the Számla Agent key the User provides. The invoice is issued in the User's name, in the User's own invoice series and with the User's own tax-authority reporting; Gammatica transmits the invoice data on the User's instruction. An invoice prepared by an automation is issued only after the User's approval.	The buyer's name, address, tax number and email address; line items, quantities, unit prices and VAT rates; the fulfilment date and the payment due date; in return the invoice number and a temporary link to the invoice image, which we store together with the issued invoice's data
Billingo (the User's own account) (new in 2.4)	Issuing invoices and proforma invoices in the User's own Billingo account with the API key the User provides, under the same rules as the previous row. The buyer's details are created in Billingo as a partner record; the document's paid status is retrieved afterwards. This connection is independent of Gammatica issuing invoices for its own fees through Billingo (section 3).	The buyer's name, tax number, EU VAT number, email address and address; line items, VAT codes, currency and payment due date; in return the document identifier, its download link and the date of payment
Meta Ads (ad account) (updated in 2.5)	In preparation — not currently available. The connection will open with Meta sign-in (OAuth); Gammatica AI will then analyse the ads at the User's request and may at most prepare paused campaign drafts — it does not launch campaigns and does not initiate ad spend. We will update this notice before the connection becomes available.	No processing at present
Google Ads (ad account) (updated in 2.10)	Connection by signing in with a Google account (OAuth, `adwords` scope): the User selects the ad account, and at the User's request Gammatica AI shows and analyses the spend and results of the campaigns. At the User's request, Gammatica creates, pauses and modifies campaigns (for example the daily budget or the ad text), and the account check applies fixes (for example correcting a disapproved ad, changing a setting, adding a negative keyword). Every change runs only after the User's prior approval; fixes are shown in a before/after preview. A new campaign is always created paused and starts only when a workspace admin launches it; a campaign can only be created with a monthly spending cap set by a workspace admin. When the account's monthly spend reaches 95% of the cap, the system pauses all running campaigns in the account and, if the User has enabled this, resumes the campaigns it paused on the 1st of the following month. If the User sets up the “won deal” conversion, Gammatica sends the value of won deals back to the Google Ads account as offline conversions, only where the contact arrived through an ad click and the visitor consented to advertising cookies. For campaign proposals and analyses, a summary of the campaign data may be passed to the AI provider (section 3.1). The refresh token is stored encrypted with AES-256-GCM and is never written to logs. On disconnection or when the workspace is deleted, we also revoke the consent at Google and delete the token and the stored account and Business Profile data; campaigns running in Google Ads keep running afterwards, but Gammatica no longer manages them. We do not sell the data and do not use it to train AI models.	The ad account ID, name, currency and time zone; the account's payment and verification status; data on campaigns, ad groups, ads and keywords (name, status, budget, ad text, landing page, spend, impressions, clicks, conversions, disapproval reasons); conversion actions; for offline conversions, the ad-click identifier (gclid, gbraid, wbraid), the time of the win, and the deal's value, currency and internal ID
Google Tag Manager (the User's own container) (new in 2.10)	Setting up ad-conversion measurement in the User's own GTM container, at the User's request (scopes: `tagmanager.readonly`, `tagmanager.edit.containers`, `tagmanager.edit.containerversions`, `tagmanager.publish`): reading the containers and the tags already published (to avoid double counting), then creating, in a separate GTM workspace, the Google tag, the conversion tags, triggers and variables, and the Consent Mode default — existing tags are left untouched. At the User's request we create and publish a new version, and can restore the previous version in one click; only a workspace admin can request publishing or restoring. If the User has no container yet, we create one in their GTM account at their request. Through the Tag Manager API we have no access to the website visitors' data. Access is part of the connection described in the Google Ads row: the refresh token is stored encrypted with AES-256-GCM; on disconnection or when the workspace is deleted, we also revoke the consent at Google and delete the token. Published tags remain in the User's container. We do not sell the data and do not use it to train AI models.	The IDs and names of GTM accounts and containers; the names, types and settings of the container's tags, triggers and variables (for example the conversion ID and label); version IDs; the address of the measured website
Google Analytics (GA4, the User's own property) (new in 2.10)	Linking the User's GA4 property with the Google Ads account, at the User's request (scope: `analytics.edit`): reading the properties and web data streams, the data retention setting and the number of key events, creating the link with the Google Ads account (with ads personalisation enabled), and, if the User has no property yet, creating a property and a web data stream at their request. Only a workspace admin can request changes in GA4. We do not read GA4 visitor reports. Access is part of the connection described in the Google Ads row: the refresh token is stored encrypted with AES-256-GCM; on disconnection or when the workspace is deleted, we also revoke the consent at Google and delete the token. We do not sell the data and do not use it to train AI models.	The IDs and names of GA4 accounts and properties; the web data stream's measurement ID (G-…) and address; the data retention setting; the number of key events; existing Google Ads links
Google Business Profile (new in 2.10)	Reading and updating the User's own Business Profile, at the User's request (scope: `business.manage`): reading Business Profile accounts and locations; linking the location to the Google Ads account so that ads also appear on the map; if there is no profile yet, creating or claiming it from the workspace's business details and starting verification (the User enters the code sent by Google); updating profile information (opening hours, website address, description); replying to reviews; uploading photos from the User's website; publishing posts; and reading reviews, the number of photos and posts, and map views to analyse the profile. Only a workspace admin can request creation and linking. The User sees and can edit any reply, description or post written by the AI before it is published, and it goes out only after their approval. To draft a reply, the review's text, star rating and the reviewer's display name are passed to the AI provider (section 3.1). Access is part of the connection described in the Google Ads row: the refresh token is stored encrypted with AES-256-GCM; on disconnection or when the workspace is deleted, we also revoke the consent at Google and delete the token and the stored location data. We do not sell the data and do not use it to train AI models.	The business name, address, phone number, website, category, opening hours and description; the Business Profile account and location IDs, the map link; the verification method and status; the star rating and text of reviews, the reviewer's display name and whether the review has been answered; the number of photos and posts; the number of map views
Google Search Console and Site Verification (new in 2.10)	Adding the User's website to Google Search Console, at the User's request, through a separate Google connection set up by a workspace admin (scopes: `webmasters`, `siteverification`): adding the website as a property and verifying it — on a page built with Gammatica we place the verification meta tag ourselves; for their own domain the User may instead add a DNS TXT record —, submitting the sitemap and checking its status, and showing search impressions, clicks, average position and top search queries. The refresh token is stored encrypted with AES-256-GCM and is never written to logs. On disconnection or when the workspace is deleted, we also revoke the consent at Google, delete the token and the websites' verification status, and remove the verification meta tag; the property remains in the User's Search Console account. We do not sell the data and do not use it to train AI models.	The website address (property), the verification token and verification status; the sitemap address and status; aggregated search data: impressions, clicks, average position and top search queries
Webshop (UNAS, WooCommerce, Shoprenter, Shopify) (new in 2.5)	Connecting the User's own webshop with a read-only API key provided by the User: products are imported and orders are synchronised — each new order creates a contact and a deal in the User's workspace, with its source marked. Gammatica changes nothing in the webshop. A Shopify store can also be connected, using the ID and secret of an app the User creates in Shopify. (updated in 2.7)	The buyer's name, email address, phone number and shipping address; the order's identifier, items, amount, currency and status; product data (name, price, stock)
Data migration (MiniCRM, Asana, Trello) (new in 2.5)	Importing data stored in the User's previous system, at the User's request and with access provided by the User. Gammatica changes nothing in the source system.	MiniCRM: contacts, deals, tasks, correspondence, notes, documents and tags. Asana and Trello: projects and tasks (title, description, due date, status), and the assignee's email address for matching with workspace members
Partner applications (OAuth connection) (new in 2.5)	Connecting an external application authorised by the User (for example Villámkalkulátor) without sharing passwords. The consent screen shows what the application requests; once approved, the application may submit leads into the workspace and may receive feedback when a deal is closed. The authorisation can be revoked at any time.	The data of leads submitted by the partner application (name, contact details, source label); the fact and outcome of a deal's closing
Gammatica MCP server (Claude, ChatGPT and other MCP clients) (new in 2.5)	The User may connect their own AI client to Gammatica's MCP server: they sign in, choose the workspace and approve access (OAuth) — the client never receives a password. At the User's request the client may query workspace data; create contacts, projects and automation drafts, and create and update tasks; and have a landing page, website, presentation, proposal or image generated, which uses AI credits. Access follows the User's actual membership and role, and can be revoked at any time among the workspace's connected applications.	The workspace data the User requests or creates from the client (for example contacts, deals, tasks, meeting notes, bookings, automations) and the results of generations started by the client
Own mailbox (IMAP/SMTP) and mailbox visibility (new in 2.7)	Connecting any mailbox with the provider's IMAP and SMTP details, to receive and send email from Gammatica; several mailboxes can be connected per workspace. By default, the email in a connected mailbox is visible only to the user who connected it ("Only me"), and the workspace admin cannot override this. The password is stored encrypted. When a mailbox is connected, we check the domain's public SPF, DKIM and DMARC records so that the email can be delivered.	Email address, mail server details and password; the subject, body, senders, recipients and attachments of the emails
MyGLS (new in 2.7)	Creating parcel labels in the User's own MyGLS account, with access details provided by the User, after the workspace admin has connected it.	The recipient's name, address and phone number; parcel details; in response, the parcel number and the label

Data from webshop, migration and partner integrations. With regard to personal data arriving from the User's webshop, previous system and partner applications — including the data of the User's buyers and leads — the User is the controller and Gammatica is the processor acting on the User's instructions. Informing the data subjects and establishing the legal basis for processing are the User's responsibility. (new in 2.5)

Legal basis	Performance of a contract (Article 6(1)(b) GDPR). Integrations only operate after the User’s activation and OAuth consent.
Retention	Until the integration is deactivated or the User’s account is deleted. Third-party providers’ own retention policies also apply.

Roles for Meta (Facebook) Lead Ads. For leads received through Meta Lead Ads, the customer operating the workspace is the data controller and Gammatica acts as a data processor on their behalf. The leads arriving through this integration come from the customer’s own advertising and Pages; Gammatica neither collects leads for itself through this integration nor uses them for its own marketing. Lead data is stored in the customer’s workspace until they delete it, and is removed when the workspace is deleted. (new in 2.3)

Keys and tokens provided by the User. Where the connection is made with an API key or access token provided by the User (Stripe, Számlázz.hu, Billingo, UNAS, WooCommerce, Shoprenter, MiniCRM, Asana, Trello) or with an OAuth token (Dropbox, Meta Lead Ads), we store the key or token encrypted, never write it to logs, and use it solely for the requests of the given integration. When the connection is ended we delete the key or token. When the Dropbox connection is switched off, the stored token immediately stops being used, but it is deleted at the User's request, which can be sent to [email protected]; we therefore recommend that the User also revoke the permission in Dropbox's own interface, which invalidates the token for good. The Meta-side permission can be revoked in Meta's interface. The data of invoices already issued and the contacts, deals, orders and notes that arrived in the User's workspace remain after disconnection until the User deletes them. (updated in 2.5)

Roles for the User's own accounts. For personal data coming from, or sent to, the User's own Stripe, Számlázz.hu, Billingo, Dropbox and ad accounts — including the data of the User's customers and buyers — the User is the controller and Gammatica is the processor acting on the User's instructions. The provider concerned processes the data under its own contract with the User and its own privacy policy. Gammatica does not use this data for its own purposes and never shares it with other customers. (new in 2.4)

2.6. Automated Decision-Making and Profiling

In accordance with Article 22 of the GDPR, the Controller informs Users that Gammatica performs the following automated processing activities:

Feature	Description and impact
AI-based lead scoring	The system automatically scores clients based on interactions. Advisory only; the final decision is made by the User.
Chatbot-based qualification	The AI chatbot pre-screens enquiries. Serves as a suggestion, not a decision with legal effect.
Automatic workflow triggers	CRM events may trigger automatic actions (e.g. email sending, status change), including via Make.com and Zapier.
AI email reply suggestion	AI analyses incoming emails and generates reply suggestions. In semi-automatic mode, final sending requires the User’s approval.
Automated sales correspondence (Full AI Sales) (new in 2.2)	Where the User selects it, the agent may send email to an enquirer in the User’s name, from their connected mailbox, without human approval, and continue the correspondence. Every such message is logged, and the User can switch back to semi-automatic mode at any time. Any message touching price, discount, contract or a complaint is returned to a human. The mode is switched on inside the User’s workspace and is off by default.
AI meeting notes (new in 2.1)	The notetaker generates a summary, main points and action items from a meeting transcript. Advisory only; the User reviews and edits the result. See Section 5.2.
AI actions in connected accounts (updated in 2.5)	On the User's instruction the AI may perform an action in a service the User has connected, for example create a payment link in the User's Stripe account, or prepare an invoice or proforma invoice in the User's invoicing account. The User sets the AI's autonomy level in the workspace: by default such an action runs only after the User's confirming click; the User may choose to let the AI perform it without confirmation. The system issues invoices only with the User's approval; in the connected webshop, in previous systems (MiniCRM, Asana, Trello) and in Dropbox the AI changes nothing. These actions are not decisions with legal effect on the natural persons concerned: the User initiates and reviews them.
Protecting the free allowance (new in 2.7)	The starter credit and the free video may be withheld on the basis of the automatic check described in section 2.2. The decision does not affect sign-up, use of the account or paid services. If the User believes they were classified incorrectly, they can request human review at [email protected].

Data Subject’s right: The User may at any time request human intervention, express their view, and contest an automated decision by contacting [email protected]. (updated 2.1)

2.8. Webshop storefront (new in 2.5)

The User may build a webshop storefront in Gammatica from their own products, with a shopping cart. When a buyer places an order, they provide their name, email address and — if the storefront asks for it — phone number; the order goes to the User's Orders module and the buyer is added to the User's workspace as a contact.

Payment. Card payment takes place exclusively through the User's own Stripe account: Gammatica opens a payment session in the User's account, the purchase price goes directly to the User, and full card data does not reach Gammatica. The billing address and tax number are collected by Stripe. Without a connected Stripe account there is no card payment; the order is then confirmed by the User. Gammatica does not handle, hold or transfer money.

Roles. With regard to buyers' data, the User is the controller and Gammatica is the processor. The User may ask for consent on the storefront by referring to their own privacy notice; informing buyers is the User's responsibility.

2.9. Quality review of AI conversations (new in 2.7)

So that Gammatica AI and the built-in help assistant (Anna) give better answers, every night we automatically review the previous day's conversations: an AI model identifies where the User received a wrong or incomplete answer. Before the review, email addresses, phone numbers and account numbers are masked in the text; of attachments, only their name and type are passed on. The text reaches the model via OpenRouter, Inc. (section 3.1).

The result — the verdict, a short masked quote and the conversation's identifiers — is stored in the platform's internal interface. Only the platform operator has access to it; if the operator opens the masked transcript behind a finding, this is logged. We use the result to improve the Service: we do not assess the User and make no decision about them.

Purpose of processing	Ensuring the quality of the Service: finding and fixing errors in AI answers.
Legal basis	Legitimate interest (Article 6(1)(f) GDPR): ensuring the quality of the Service. The User may object (section 6.4).
Data processed	The masked text of AI conversations (the messages of the day concerned and a shortened part of the earlier history); the finding: verdict, category, severity, short masked quote and identifiers.
Retention period	Findings are kept for 12 months from when they are recorded.

2.10. Booking page: guests, attendance, deposits (new in 2.7)

On the User's booking page, the person booking may — if the event type allows it — add further guests (their name and email address) after accepting the notice that applies to guests. Guests receive the confirmation and the calendar invitation and are added to the User's workspace as contacts, but only in connection with the booking: no deal, automation or marketing email is started for them. In the reminder, the person booking can indicate whether they will attend; from these responses and the "No-show" flag, the User sees attendance statistics.

Deposit. If the User asks for a deposit, payment is made in the User's own Stripe account, on Stripe's payment page: the money goes directly to the User, and full card details never reach Gammatica. On cancellation, refunds are made from the User's Stripe account according to the rule the User has set. Alongside the booking, we store the payment's identifier, amount, currency and status.

Roles. For the data of people booking and their guests, the User is the controller and Gammatica is the processor; informing the data subjects is the User's responsibility.

2.11. The AI machine: a cloud browser for the User's tasks (updated in 2.11)

The AI machine is an isolated browser running in the cloud which, at the User's express request, works on websites on the User's behalf: it researches companies, compares prices, fills in forms (the User authorises submission on an approval card) and — if the User logs in — checks data in the User's own account. The machine goes to sleep or ends when the task is finished; it never starts on its own.

Who is the controller? For the personal data the machine collects or sends for the User's task (for example the names and business contact details of contacts found in company research, data sent in a form, or third parties' data appearing on the web pages the machine opens), the User (or the workspace on whose behalf the User acts) is the controller; Gammatica acts as processor, on the User's instructions. Gammatica processes the operations log as controller for its own purposes — operating the service securely, preventing abuse and accounting for the credits used.

Data processed	The User's request (the task text) and the result of the task (for example the companies and prices found, the list of downloaded documents); the addresses of the websites visited and the content needed for the task (including third parties' data appearing on them); frames captured from the machine's screen — only for the live view during the run and to keep the User informed (no frames are kept, and none at all after logging in to the User's own account); data sent in a form (only after the User's approval); if the User saves them: login details bound to a website (secret store) — encrypted, usable only by the User who saved them, and by other team members only if expressly shared; if the User logs in to a site on the machine and the machine stays in sleep mode: the login session (cookies) on the machine, encrypted — their values never leave the machine, and the interface shows only the website's name; the operations log: who started which task, when, on which websites, its result and how many credits it used. Typed passwords and codes are never logged.
Purpose and legal basis	Carrying out the task requested by the User: performance of a contract (Article 6(1)(b) GDPR). For data of third parties affected by the task (for example an employee listed on a public company page), the legal basis is provided by the User as controller; for business outreach this is typically legitimate interest (Article 6(1)(f)). The operations log: Gammatica's legitimate interest in secure operation and abuse prevention (Article 6(1)(f)), and accounting.
Recipients	FoundryLabs, Inc. (E2B) — running the machine; OpenRouter, Inc. and the AI model providers it reaches — interpreting the task and controlling the machine (Section 3.1; OpenRouter does not log the content or use it for AI training); the operators of the websites on which the machine works at the User's request — only the data the User sends with approval. Transfers to the USA take place with the safeguards set out in Section 4 (SCC).
Retention	Live frames: only for the duration of the run. The task's result in the conversation: until the conversation or the account is deleted. Secret store: until the User deletes it or the account or workspace ends. The sleeping machine and the login sessions on it: at most 30 days without use; we notify the User by email 7 days and 1 day before deletion, and the User can extend it with one click. The User can delete the machine at any time ("Reset machine"), and it is deleted immediately when the account, the workspace or the membership ends. Operations log: under the general rule for security logging (Section 2.2). The fact that the consent screen was accepted: for as long as the account data.

Security. For every run the machine runs in an isolated environment with its own network restrictions, behind a filtering proxy. Saved login details (the username and password bound to a website) and the login sessions remaining on the machine (cookies) are stored encrypted: login details until the User deletes them from the secret store or the account or workspace ends, sessions for at most 30 days without use; the User can sign the machine out of a site at any time and delete all sessions with "Reset machine". The AI model never sees the password, and the machine types it in only on the site it is bound to. The machine submits a form only with the User's approval — the approval card shows the data actually to be sent and the receiving address; an "Always on this site" permission can be revoked. The machine does not open banking, payment or checkout pages, does not circumvent websites' protections (for example CAPTCHA) and respects robots.txt. During a takeover the User clicks and types on the machine's screen; what the User types is not recorded. No automated decision-making takes place.

Data subjects' rights. The User can delete and export their data in their account. Anyone who believes that a Gammatica User has processed their data with the AI machine can contact that User as controller; Gammatica helps forward the request via its data protection address.

2.12. Mobile app (iOS and Android) (updated in 2.15)

In the Gammatica mobile app, an account can be created with an email address and password, or with an Apple or Google account (in that case Apple or Google passes on the name and email address, with the User’s approval; with Apple sign-in, the email address may be a private relay address), and users can also sign in with an existing account. The app is available in Hungarian, English, Polish and Romanian. It shows and handles the same workspace data as the web interface (for example team chat, tasks, sales, projects, proposals, contract signing), and sections 2.2 to 2.11 apply to it. The following is processing specific to the mobile app.

Device data. At sign-in we record the device platform (iOS or Android), the app version and the time of last use, and we keep a record of the device under an identifier. The User can request remote sign-out of a device at [email protected].
Push notifications. If the User allows them on the phone, we store the device’s notification identifier (push token) on our server and send notifications directly through Apple (APNs) or Google (Firebase Cloud Messaging). A notification may include a preview of the message; the preview can be hidden on team chat notifications. In the app settings, team chat notifications can be switched off per channel or entirely, and task reminders with a separate switch; all notifications can be switched off in the phone’s system settings. After sign-out we send no notifications to the device. We delete the push token when Apple or Google reports it as invalid, when the device is signed out remotely, or when the account is deleted.
Data stored on the phone. Sign-in tokens are stored only in the phone’s protected storage (iOS Keychain, Android Keystore). So that the app opens quickly even without a network, it also keeps team chat channels and messages, unsent messages, and the User’s name, email address and list of workspaces in the phone’s local storage. On sign-out, these, the tokens, the search history and downloaded files are deleted from the phone, and if there is a network connection the session is also revoked on our server. Sign-out does not currently clear the system image cache of viewed images or the temporary copies of files selected for attachment: these may stay on the phone until the phone’s system clears them or the User deletes the app. The device identifier, the identifier of the last used workspace, the language and theme settings and a few technical flags (for example, that the notification question has already been shown) also stay on the phone after sign-out.
Camera, photos, files, microphone. The app accesses the camera, photos and files only when the User attaches an image, video or file (team chat, comments, contacts, AI, signature, website) and the phone asks for permission. The selected item is uploaded to the workspace; if the User attaches it to the AI, it also reaches the AI providers listed in section 3.1. The app reads no other images or files. When a larger piece of text enters the input field (for example by pasting), the app reads the clipboard on the phone to keep the formatting; it does not otherwise store or send the clipboard’s content. The microphone and speech recognition are used only for dictation in the message field: speech is converted to text by the phone’s system speech recognizer (Apple’s or Google’s service), and only the finished text goes into the field; Gammatica does not receive or store the audio.
Software updates. At launch, the app checks with the Expo service (650 Industries, Inc.) whether a new version is available, and downloads the update from there. For this, the IP address, a random identifier tied to the app installation, the platform and the version reach Expo; workspace data does not.
Passkeys. In the app, the User can also sign in with a passkey, and can create and delete passkeys in Settings. For this, the app uses the phone’s built-in passkey support and the User’s password manager; the app does not receive fingerprints or face images. Details are in the “Signing in with a passkey” part of Section 2.2.
No tracking. The app contains no analytics, advertising or crash-reporting tools, uses no advertising identifier, and does not track the User across other apps or websites.

Purpose	Running the mobile app: sign-in, keeping a record of devices, sending notifications, offline use, software updates.
Legal basis	Performance of contract (Article 6(1)(b) GDPR). The User turns on push notifications through the phone’s permission and can turn them off at any time.
Data processed	Registration data (name, email address, password, or with Apple or Google sign-in the name and email address received from the provider), device platform, app version, time of last use, push token; technical data reaching Expo (IP address, installation identifier, platform, version); images, videos and files attached by the User.
Retention period	Device data until the account is deleted; the push token until Apple or Google reports it as invalid, the device is signed out remotely or the account is deleted. Data stored on the phone until sign-out or until the app is deleted, with the exceptions above; on iOS, items in protected storage may remain after the app is deleted until the phone’s system removes them.

3. Recipients, Data Transfers, Data Processors

Users’ personal data may be transferred or made available to:

Name	Contact	Purpose / task	Location
VAMOSOFT Kft.	2310 Szigetszentmiklós, Kert u. 6. · [email protected]	Software development, support	Hungary
Szigeti-Korán	1132 Budapest, Visegrádi u. 48. · [email protected]	Accountant	Hungary
DigitalOcean LLC	101 6th Ave, New York · [email protected]	Hosting service	USA
Stripe Payments Europe Ltd.	Grand Canal St Lower, Dublin · [email protected]	Online payment system	Ireland
Billingo Technologies Zrt.	1133 Budapest, Árbóc u. 6. · [email protected]	Online billing system (Gammatica's own invoicing); and the User's own Billingo account, if the User connects it (updated in 2.4)	Hungary
Make.com (Celonis SE)	Thomas-Dehler-Str. 14, Munich · [email protected]	Automation workflows	Germany
Google LLC (Gmail, Calendar, Workspace)	1600 Amphitheatre Pkwy, Mountain View · [email protected]	Email & calendar integration, OAuth; connection of Google Ads, Google Tag Manager, Google Analytics (GA4), Google Business Profile, and Google Search Console and Site Verification at the User's request (section 2.5); in the mobile app, delivering push notifications (Firebase Cloud Messaging), sign-in with a Google account and, on Android, the system speech recognizer (updated in 2.13)	USA
Microsoft Corp. (Outlook)	One Microsoft Way, Redmond · [email protected]	Email & calendar integration	USA
PostHog Inc. (EU Cloud)	EU hosting: Frankfurt (AWS eu-central-1) · [email protected]	Product analytics, user behaviour analysis	EU (Germany)
Hyperdoc Inc. (Recall.ai) (new in 2.1)	2261 Market Street #4339, San Francisco, CA 94114, USA · [email protected]	Meeting-bot infrastructure (recording and transcript) for the AI Meeting Notetaker	EU data region (eu-central-1)
ActiveCampaign, LLC (Postmark) (new in 2.1)	1 North Dearborn Street, 5th floor, Chicago, IL 60602, USA · [email protected]	Transactional email delivery (welcome messages, notifications)	USA
Bird B.V. (MessageBird) (new in 2.1)	Keizersgracht 268, 1016 EV Amsterdam, The Netherlands · [email protected]	Delivery of SMS and WhatsApp messages, receiving incoming email, and delivery of campaign email from the User's own sending domain for workspaces not yet moved to Amazon SES (updated in 2.9)	Netherlands (EU)
Amazon Web Services EMEA SARL (Amazon SES) (new in 2.9)	38 Avenue John F. Kennedy, L-1855 Luxembourg · [email protected]	Delivery of newsletters and campaign emails that workspaces send from their own sending domain, and processing of delivery events (delivered, opened, bounced, complaint, unsubscribed) for statistics and list hygiene (Amazon SNS/SQS). Data concerned: the recipient's email address, their name where the email uses it, the message content, sending metadata and event data.	Sweden (EU), eu-north-1
Zapier, Inc. (new in 2.1)	548 Market St. #62411, San Francisco, CA 94104-5401, USA · [email protected]	Automation platform — only if the User connects it	USA
Dropbox, Inc. (new in 2.4)	1800 Owens St, San Francisco, CA 94158, USA · [email protected]	File storage integration — only if the User connects it; read access	USA
KBOSS.hu Kft. (Számlázz.hu) (new in 2.4)	1031 Budapest, Záhony utca 7. · [email protected]	The User's own invoicing account — invoice data transmitted on the User's instruction, only if the User connects it	Hungary
Meta Platforms Ireland Ltd. (new in 2.4)	Merrion Road, Dublin 4, D04 X2K5, Ireland · facebook.com/privacy	Lead Ads integration — only if the User connects it; lead data arrives from Meta. Connecting an ad account is in preparation, no processing at present (updated in 2.5)	Ireland / USA
Cloudflare, Inc. (new in 2.7)	101 Townsend St, San Francisco, CA 94107, USA · [email protected]	DNS, encrypted connection (TLS), routing and protection of traffic in front of the website and the application	USA / global network
FoundryLabs, Inc. (E2B) (new in 2.7)	San Francisco, CA, USA · e2b.dev	Isolated runtime: data analysis, animation and video rendering, and the AI machine (cloud browser, with the logins that remain on it) (extended in 2.8)	USA
Apple Inc. (updated in 2.15)	One Apple Park Way, Cupertino, CA 95014, USA · apple.com/privacy	Sign-in with an Apple account on the web interface and in the mobile app; in the mobile app on iOS: delivering push notifications (Apple Push Notification service) and the system speech recognizer during dictation	USA
650 Industries, Inc. (Expo) (new in 2.13)	USA · expo.dev	Delivering software updates for the mobile app. Data involved: IP address, a random identifier tied to the app installation, platform, version.	USA

Recipients chosen by the User. The partner applications and MCP clients described in Section 2.5 (for example Claude or ChatGPT) receive data from the workspace on the User's instructions. They are not Gammatica's processors but recipients chosen by the User, which process the data under their own terms and privacy notices. (new in 2.5)

3.1. AI Service Data Processors

Gammatica’s AI features operate through OpenRouter, Inc., which routes requests to AI model providers.

Provider	Location	Task	Data retention
OpenRouter, Inc.	USA (New York)	Routing AI requests (proxy)	Prompt/response logging disabled; OpenRouter does not retain prompt or response content. AI-training opt-out enabled, so requests are not routed to providers that train on the data.
AI model providers (sub-processors)	USA / EU / varies (see Section 4)	Running language models, text generation, email reply generation, meeting summaries	Requests are routed only with the AI-training opt-out applied, so providers do not use prompts or responses to train AI/ML models. Any retention is transient and governed by each provider’s own data-processing terms.

Sub-processors (model providers reached through OpenRouter): Anthropic (Claude — text and agent features), OpenAI (image generation; transcription of audio recordings), xAI (speech synthesis; Grok Imagine — video), Google (speech synthesis; Veo — video; Lyria — music), ByteDance (Seedance — video), Kuaishou (Kling — video), HeyGen (talking portrait avatars), Fish Audio (own voice — speech from the User's voice sample). The User may choose the model that creates a video; the default is Seedance. Current list: openrouter.ai/docs/guides/privacy/logging (updated in 2.5)

Version 2.7 extends the list: Black Forest Labs (image generation), ElevenLabs and Microsoft (speech synthesis). AI animations and some videos are rendered in E2B's isolated environment (section 3). The built-in help assistant's live voice call — currently not available in every account — connects directly to OpenAI: during the call, the User's voice and name reach it. (new in 2.7)

4. Data Transfers to Third Countries (Outside the EEA)

Personal data may be transferred outside the European Economic Area (EEA) with the following safeguards:

Provider	Destination	Safeguards applied
DigitalOcean LLC	USA	EU-U.S. Data Privacy Framework (DPF); Standard Contractual Clauses (SCC)
OpenRouter, Inc.	USA	Standard Contractual Clauses (SCC); prompt/response logging disabled and AI-training opt-out enabled
AI model providers	USA / varies	OpenRouter’s privacy settings ensure transfers only to providers with adequate safeguards
Stripe Payments Europe	Ireland / USA	EU-U.S. Data Privacy Framework; Stripe DPA
Google LLC	USA	EU-U.S. Data Privacy Framework; Google DPA; Standard Contractual Clauses
Microsoft Corp.	USA	EU-U.S. Data Privacy Framework; Microsoft DPA; Standard Contractual Clauses
ActiveCampaign, LLC (Postmark) (new in 2.1)	USA	EU-U.S. Data Privacy Framework; Standard Contractual Clauses
Zapier, Inc. (new in 2.1)	USA	EU-U.S. Data Privacy Framework; Standard Contractual Clauses
Dropbox, Inc. (new in 2.4)	USA	EU-U.S. Data Privacy Framework; Standard Contractual Clauses
Meta Platforms Ireland Ltd. / Meta Platforms, Inc. (new in 2.4)	Ireland / USA	EU-U.S. Data Privacy Framework; Meta's Standard Contractual Clauses (SCC)
Cloudflare, Inc. (new in 2.7)	USA	EU-U.S. Data Privacy Framework; Standard Contractual Clauses
FoundryLabs, Inc. (E2B) (new in 2.7)	USA	Standard Contractual Clauses (SCC)
Apple Inc. (new in 2.12)	USA	EU-U.S. Data Privacy Framework; Standard Contractual Clauses
650 Industries, Inc. (Expo) (new in 2.13)	USA	Safeguards under the provider’s data processing terms

Make.com (Celonis SE, Germany), PostHog EU Cloud (Frankfurt, Germany), Bird B.V. (Netherlands), Amazon Web Services (Amazon SES, Stockholm, eu-north-1) and the Recall.ai meeting-bot infrastructure (EU, eu-central-1) store data within the EEA and do not constitute third-country transfers. Amazon Web Services belongs to a US-parented group; should the data be accessed remotely from outside the EEA, the EU-U.S. Data Privacy Framework and the Standard Contractual Clauses (SCC) serve as safeguards. (updated in 2.9)

Data Subject’s right: A copy of the safeguards can be requested at [email protected]. (updated 2.1)

5. Cookies and Web Tracking (updated in 2.14)

The gammatica.com website. Non-essential tracking code loads only if the visitor consents in the cookie banner. The exception is Google Analytics: it also loads without consent, but in that case, under Google's Consent Mode, it sets no cookies and sends only aggregated signals without identifiers.

Cookie / tool	Purpose	Legal basis	Lifetime
Google Analytics 4	Website traffic analysis, visitor statistics	Consent (Article 6(1)(a) GDPR); without consent, cookieless signals without identifiers	26 months
Google Tag Manager and the Google Ads measurement it loads	Managing tracking code, measuring sign-ups that come from ads	Consent (Article 6(1)(a) GDPR)	Google Ads cookies: 90 days
Meta Pixel	Measuring ad campaigns, remarketing	Consent (Article 6(1)(a) GDPR)	90 days
Meta Conversions API	Server-side conversion tracking	Consent (Article 6(1)(a) GDPR)	90 days
PostHog (EU Cloud)	Analysing visitor behaviour and recording visits (session recording) to improve the website; the recording masks the content of input fields	Consent (Article 6(1)(a) GDPR)	12 months
gm_src (Gammatica, first party) (new in 2.7)	Recording where the visitor came from (campaign parameters, referring page, path of the first page opened) so that the application records this source at sign-up. Without consent no cookie is set: the same signals are only added to links pointing to the application when they are clicked.	Consent (Article 6(1)(a) GDPR)	7 days
The consent decision and convenience settings (in the browser's local storage)	Remembering the decision made in the cookie banner; remembering whether the visitor has closed a pop-up	Legitimate interest (Article 6(1)(f) GDPR): needed for the website to work	Until the visitor deletes it or changes their decision

The application (app.gammatica.com).

Cookie / tool	Purpose	Legal basis	Lifetime
Sign-in cookies	Maintaining and protecting the signed-in session (HttpOnly, Secure)	Performance of contract (Article 6(1)(b) GDPR); strictly necessary to provide the Service	Access token: 15 minutes; refresh token: 30 days
PostHog (EU Cloud) — product analytics	Measuring which features are used, where use gets stuck and which errors occur in the browser. We measure page loads, named events sent from the code and errors, linked to the User Account's ID, name and email address. There is no screen recording and no automatic click capture.	Legitimate interest (Article 6(1)(f) GDPR): operating and improving the Service. The User may object (section 6.4).	12 months
Google Tag Manager and ad measurement	Measuring sign-ups that come from ads	Consent (Article 6(1)(a) GDPR), given in the cookie banner or the preference centre	Google Ads cookies: 90 days; Meta: 90 days

Pages published by Users. On the websites, forms, booking, quote and payment pages that Users build with Gammatica, third-party tracking code (such as an advertising pixel or analytics) runs only if the User sets it up, and even then behind the User's own cookie banner. On these pages Gammatica measures how the page is used, on the User's behalf as a processor, without cookies or the browser's local storage and in aggregate, so that the User can see the page's statistics: page views together with the referring page (where the visitor came from) and the funnel step, clicks on the configured conversion button and, since 11 November 2026, the Heatmap on published landing pages and websites. The User, as controller, is responsible for informing visitors (see the Terms of Service).

Heatmap. The visitor's browser sends the position of the clicked element in the page structure, the position of the click within the element and on the page, whether it was a rapid, repeated (“rage”) click, the maximum scroll depth and the visible screen height relative to the page length, and a device type derived from the screen width (desktop, tablet, mobile). We do not record keystrokes, form content, page text, mouse movement or session recordings, we do not read the browser type, and we do not identify the visitor. We use the IP address only to limit abuse, as a one-way hash held in memory, and we do not store it with the heatmap data. On high-traffic pages measurement is sampled. The data is stored as daily per-page aggregates, kept for 90 days, and deleted immediately when the page or the workspace is deleted.

These pages load fonts from Google Fonts, in which case the visitor's browser connects directly to Google and its IP address reaches Google. The application's contact map uses OpenStreetMap: the displayed addresses and the User's IP address reach it.

PostHog EU Cloud: Analytics data is stored within the EU, in Frankfurt (AWS eu-central-1). IP address capture is switched off.

Managing cookies: Visitors can accept or reject non-essential cookies in the cookie banner shown on their first visit, and can change their decision at any time.

5.1. Google Workspace API (rewritten in 2.1)

Data obtained through Google Workspace APIs is not used to develop, improve, or train generalized, non-personalized artificial intelligence (AI/ML) models. Google user data is used solely to provide the features you have requested, and is never transferred or sold for advertising purposes.

Google user data we access

Gammatica requests the following Google OAuth scopes, and only these:

Basic profile (openid, email): your name and email address, used to identify the connected account inside Gammatica.
Gmail — read (gmail.readonly): we read messages so that your customer conversations appear on the contact timeline and in the Conversations inbox. We never read mailboxes of anyone other than the connecting user.
Gmail — send (gmail.send): we send emails on your behalf only when you (or an automation you configured) explicitly initiate sending.
Google Calendar (calendar.events): we read your calendar events to show your upcoming meetings, to prevent double-booking on your public booking page, and to schedule the AI Notetaker for meetings you asked it to join. We write to your calendar in one specific case: when a guest books a time slot on your public Gammatica booking page, we create the corresponding event in your calendar (with the guest as an attendee and, if requested, a Google Meet link), and we delete that event if the booking is cancelled. We never modify or delete any other events.
Google Ads (adwords): we read the campaign data of your ad account and, at your request and with your prior approval, create, pause and modify campaigns, apply fixes, and send back offline conversions (section 2.5). (new in 2.10)
Google Tag Manager (tagmanager.readonly, tagmanager.edit.containers, tagmanager.edit.containerversions, tagmanager.publish): reading your own container, adding conversion tags, and creating and publishing a version at your request (section 2.5). (new in 2.10)
Google Analytics (analytics.edit): linking your GA4 property with your Google Ads account and, where needed, creating a property and a web data stream (section 2.5). (new in 2.10)
Google Business Profile (business.manage): reading and updating your business profile at your request (section 2.5). (new in 2.10)
Google Search Console and Site Verification (webmasters, siteverification): adding and verifying your website, submitting the sitemap, and showing impressions and clicks (section 2.5). (new in 2.10)

We request no other Google scopes (no Google Drive, no Contacts).

Google user data is never sold. Data is only shared with third parties with User consent, for legal compliance, or with service providers bound by confidentiality agreements.

5.1.1. Data Protection Mechanisms for Google User Data

Gammatica implements the following technical and organizational measures to protect Google user data accessed through Google Workspace APIs. These measures are in addition to the general data security measures described elsewhere in this Privacy Policy:

Encryption: All data transmitted between Gammatica and Google services is encrypted using TLS 1.2 or higher (HTTPS). Google OAuth tokens and refresh tokens are encrypted at rest using AES-256 encryption and are stored separately from other application data.

Access Control: Access to Google user data within the Gammatica platform is governed by role-based access control (RBAC). Only authenticated and authorized users within a workspace can access data obtained through Google integrations. Internal staff access to production systems containing Google user data is restricted to essential personnel only and is logged.

Token Security: Google OAuth access tokens and refresh tokens are never:

logged in application logs or error reports;
displayed in user interfaces;
transmitted to third parties;
stored in client-side code or browser storage.

Tokens are stored server-side in encrypted form and are automatically revoked when the user disconnects the Google integration from their Gammatica account.

Data Isolation: Each workspace’s Google integration data is logically isolated. Users in one workspace cannot access Google data belonging to another workspace.

Monitoring and Incident Response: Gammatica maintains system monitoring to detect unauthorized access attempts to Google user data. In the event of a data breach involving Google user data, Gammatica will notify affected users and Google within 72 hours in accordance with GDPR Article 33.

Data Minimization: Gammatica requests only the minimum OAuth scopes necessary for functionality — the scopes listed in Section 5.1 and no others. Gammatica does not request or store full Gmail mailbox access beyond what is necessary for the features activated by the user. Calendar write access is used solely to create and delete the events generated by your own Gammatica booking page; no other events are modified or deleted. (updated in 2.10)

Data Retention and Deletion: Google OAuth tokens are retained only while the user’s Google integration is active. When a user disconnects their Google account or deletes their Gammatica workspace, all associated Google tokens and cached Google data are permanently and immediately deleted from Gammatica’s systems.

Regular Security Reviews: Gammatica conducts periodic security reviews of its integration with Google APIs to ensure continued compliance with the Google API Services User Data Policy and applicable data protection regulations.

5.1.2. Google API Services Limited Use Disclosure

Gammatica’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

Gammatica will only use access to Google user data to provide and improve user-facing features that are prominent in the application’s user interface.
Gammatica will not transfer Google user data to third parties unless necessary to provide or improve user-facing features, to comply with applicable law, or as part of a merger, acquisition, or sale of assets with prior user notice.
Gammatica will not use Google user data for serving advertisements.
Gammatica will not allow humans to read Google user data unless the user has provided affirmative consent, it is necessary for security purposes, to comply with applicable law, or the data is aggregated and anonymized for internal operations.

5.2. AI Meeting Notetaker (new in 2.1)

If you enable the notetaker, a clearly labelled bot participant (“Gammatica AI-jegyzetelő”) joins the video meetings you selected (auto-join can be turned off per user at any time). The bot records the meeting audio/video and produces a transcript; from the transcript we generate a summary, main points, topics and action items.

Data processed: meeting audio/video stream, transcript, the meeting title and time, and the attendees’ email addresses (used solely to match the meeting to your existing CRM contacts).
Where it goes: the finished note is stored in your workspace. If the “note to contact timeline” setting is on (default, can be switched off), the summary and transcript excerpt are also posted as a note on the matched contact’s timeline, and action items become tasks.
Sub-processor: the meeting bot infrastructure is provided by Recall.ai (data region: EU, eu-central-1). Recall processes the recording on our instruction and does not use it for its own purposes.
AI processing: transcripts are summarized via OpenRouter, Inc. under the same safeguards as our other AI features (logging disabled, no routing to providers that train on the data).
Your responsibility: you must inform meeting participants that the meeting is being recorded and obtain any consent required by applicable law before inviting the notetaker. The bot always appears as a visible, named participant.
Retention & deletion: notes and transcripts remain until you delete them or your account; disconnecting the calendar or turning off auto-join stops any future recording immediately.

6. Data Subject’s Rights

6.1. Right of Access

Data Subjects may request information on whether their data is processed, what data, on what basis, for what purpose, for how long, and whether automated decision-making applies. The first copy is free.

6.2. Right to Rectification

The Data Subject may request rectification of inaccurate data. The Controller shall comply within one month.

6.3. Right to Restriction of Processing

The Data Subject may request restriction where: accuracy is contested; processing is unlawful; the Controller no longer needs the data; or the Data Subject has objected.

6.4. Right to Object

The Data Subject may object to processing if they consider the Controller is handling data inappropriately.

6.5. Right to Erasure (“Right to Be Forgotten”)

The Data Subject may request erasure where: consent is withdrawn; the purpose has ceased; processing is unlawful.

How to request deletion. Write to [email protected] from the email address the data concerns, stating what should be deleted. We acknowledge the request and complete the deletion within one month. Data that reached Gammatica through an integration — including leads from Meta (Facebook) Lead Ads — sits in the workspace of the customer who is its data controller: we forward the request to them without delay and carry out the deletion in the workspace within one month of receiving the request; in every case the data is removed when the workspace itself is deleted. (new in 2.3)

Deleting your account. (updated in 2.15) You can delete your account yourself: in the mobile app under Settings › Delete account, by typing your email address; on the web interface under Settings › Profile, with the “Delete account permanently” button; or without signing in at https://app.gammatica.com/fiok-torles, using a confirmation link sent by email. If you are the only admin of a workspace with other members, you must first hand over admin rights or delete the workspace. Deletion is immediate: the name, email address, password, profile picture, email signatures, two-factor authentication data, passkeys, sessions, signed-in devices and push tokens are deleted, memberships end, and the account can no longer be used to sign in. What is kept: the team’s shared work (comments, history) under the name “Deleted user”; a single-person workspace closes, but its content (contacts, cards, files, conversations, data of connected integrations) is not deleted from our servers when it closes, and you can request its permanent deletion from your account address at [email protected], which we complete within one month; billing data for 8 years after the financial year concerned; security log entries, which may contain the email address, for the period stated in section 2.2; the anonymous record of the account, without name or address, and, if you received the starter package, a one-way hash of the email address on that record, to prevent repeated claims of the free allowance. Deletion does not start a separate cancellation or a refund; the subscription of a shared workspace stays with the team. You can also request deletion at [email protected].

6.6. Right to Data Portability

The Data Subject may request their data in a structured, machine-readable format where processing is consent-based and automated.

6.7. Right to Legal Remedy

If you believe your rights have been infringed, contact us at [email protected]. (updated 2.1)

If your complaint cannot be resolved, you may lodge a complaint with:

Authority	Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Address	1055 Budapest, Falk Miksa utca 9–11, Hungary
Postal address	1363 Budapest, Pf.: 9.
Phone	+36 (1) 391-1400
Email	[email protected]

The Data Subject may also seek judicial remedy before the court of their habitual residence or domicile.

Budapest, 24 September 2026
Gammatica Kft.
Viktor Dániel Várhegyi, Managing Director