Privacy Policy

This policy explains how Vlas Dmitrenko PR IT usluge TruSend Beograd (Savski Venac) (“TruSend”, “we”) processes personal data when you use trusend.ai and the TruSend platform, the purposes and legal bases for that processing, and your rights. Questions about this policy can be sent to privacy@trusend.ai.

Who is responsible

The controller is Vlas Dmitrenko PR IT usluge TruSend Beograd (Savski Venac), a sole proprietorship (preduzetnik) registered with the Serbian Business Registers Agency (APR) in the Republic of Serbia (registration number 68677424, tax identification number (PIB) 115837343), with its registered seat at Bulevar Vudroa Vilsona 8v, 11000 Beograd (Savski Venac). Full identification is on the company details page. You can contact us about any matter relating to personal data at privacy@trusend.ai.

Representative

We value your privacy and your rights as a data subject, and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the European Union under article 27 GDPR. The appointed entity is Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Vienna, Austria.

Prighter gives you an easy way to exercise your privacy-related rights — for example a request to access or erase personal data. To contact us through our representative, or to make use of your data subject rights, visit app.prighter.com/portal/TruSend. You are not required to contact us through our representative; you may also write to us directly at privacy@trusend.ai.

powered by Prighter

Our role as controller and as processor

TruSend is operated from the Republic of Serbia. For data about you as our customer — your account, workspace settings, billing — we are the data controller. For the personal data of your customers processed through your workspace — conversations, contacts and knowledge-base content — we act as a processor on your behalf and on your documented instructions. That processing is governed by our Data Processing Agreement, which forms part of the Terms of Service and takes effect when you create a workspace. If you are a customer of a business that uses TruSend, that business is the controller of your personal data: please read its privacy notice and direct requests about your data to it. Requests we receive about such data are passed to the business concerned where we can identify it.

What we collect

• Account data — name, email address, workspace name and the settings you configure. If a workspace administrator invites you, we receive your email address from that administrator; if you sign in with Google, we receive your name and email address from Google and use them only to create your account and sign you in.
• Conversation data — messages, attachments and metadata processed through your connected channels, used to operate the inbox and ground AI answers in your knowledge base. We process this data as a processor on behalf of the workspace owner, as described above.
• Data from channels and integrations a workspace connects — when a workspace connects Telegram, WhatsApp, Facebook Messenger, Instagram or email, we receive the messages sent to it through that channel and send its replies back through that channel; these messages are kept with the workspace’s conversation data (see How long we keep it). When it connects Shopify, we look up the Shopify customer whose email address matches the contact and show their name, email address, phone number, tags, order count, total spent and recent orders in the conversation. When it connects WordPress, the TruSend plugin sends us the page on which the chat was opened and the visitor’s user role on that site. We process this data as a processor for the business that owns the workspace, only to run its inbox and AI answers, and share Shopify and WordPress data only with the providers listed on the subprocessors page. Shopify and WordPress details are deleted 30 days after they were last refreshed, and Shopify data also when Shopify asks us to delete it.
• Google Docs connected as a knowledge source — if a workspace administrator connects a Google account, we access only the documents the administrator picks in Google’s file picker (Google Drive drive.file permission) and the email address of that Google account. We import the content of those documents into the workspace knowledge base and use it only for the knowledge base and AI answers; we do not use it for advertising or to train AI models, and share it only with the providers on the subprocessors page. The administrator has 15 minutes after signing in with Google to pick documents. After that, we keep an encrypted access token so the picked documents can be re-imported on the source’s schedule, until the administrator removes the source or revokes access in their Google account.
• Usage data — which parts of the platform are used and when, recorded by our servers as events (for example, a conversation assigned or resolved, a channel connected, or the AI enabled), without the content of those events. Usage data is linked to pseudonymous account and workspace identifiers, not to a name or an email address. Inside the app, the screens you open and their loading times are recorded only if you accept analytics in the app. When you create a workspace, we also record how you reached us: the campaign parameters of the link you followed or the referring website, and the page of this site from which you signed up. We do not record your browsing history.
• Billing data — payments are processed by Paddle.com Market Ltd, our merchant of record, which acts as the seller and processes your payment details as an independent controller under its own privacy notice. We receive from Paddle the information needed to manage your subscription, such as your Paddle customer identifier, plan, subscription status and transaction status. We do not receive or store full card numbers.
• Messages you send us — email and the chat on this site, used to answer you. Replies in the chat may be written by our AI agent, as described under AI processing below.

Purposes and legal bases

• Performance of a contract (GDPR art. 6(1)(b); Law on Personal Data Protection, art. 12(1)(2)) — creating and administering your account and workspace, providing the service and managing your subscription, and answering your enquiries and support requests, including steps you ask us to take before entering into a contract. Where an enquiry is not connected with a contract, we answer it on the basis of our legitimate interest in responding to people who contact us (GDPR art. 6(1)(f); Law on Personal Data Protection, art. 12(1)(6)).
• Legitimate interests (GDPR art. 6(1)(f); Law on Personal Data Protection, art. 12(1)(6)) — keeping the service secure and preventing abuse, and understanding how the platform is used and how customers find us in order to improve it (the usage data our servers record, including how you reached us when you signed up), and handling payment and billing disputes. We do not use this data to profile you. You can object to this processing at any time — see Your right to object below.
• Consent (GDPR art. 6(1)(a); Law on Personal Data Protection, art. 12(1)(1)) — audience and page-speed measurement on this site, keeping your chat in your browser between visits, and error monitoring and product analytics that run in your browser inside the app. Storing or accessing information on your device that is not strictly necessary also requires your consent under the ePrivacy rules and Serbia’s Law on Electronic Communications. You can withdraw consent at any time; withdrawal does not affect the lawfulness of processing carried out before it.
• Legal obligation (GDPR art. 6(1)(c) with art. 7(1); Law on Personal Data Protection, art. 12(1)(3) with art. 15(1)) — we keep a record of the consent choices made in the chat widget on this site so that we can demonstrate consent. Our tax records concern Paddle’s payouts to us and do not contain customers’ names, contact details or payment details.

What we do not do

• We do not sell personal data — yours or your customers’.
• We do not use personal data — yours or your customers’ — to train AI models.

How long we keep it

• Workspace and conversation data — for as long as your workspace exists, subject to any contact retention policy set in the workspace. A deleted workspace and the files stored with it are deleted from production systems 30 days after the workspace is deleted, a period during which it can be restored, and from database recovery history within a further 7 days; copies in our database provider’s own encrypted backups expire within 30 days.
• Account data — deleted with the workspace, except billing records (Paddle customer and subscription identifiers and the usage on which charges were based), which we keep for as long as a payment or billing dispute about them remains possible.
• Enquiries and support conversations — for as long as you have a TruSend account; otherwise 24 months from your last message. A message thread that evidences a contract, a complaint or a legal claim is kept until the applicable statutory limitation period expires.
• Operational logs — up to 90 days: 14 days for logs and traces and up to 90 days for application error reports. They are kept to operate and secure the service. Logs record the IP address of each request. Request bodies are not written to logs, and email addresses are masked before logs are sent to our monitoring provider; error reports may contain personal data included in the requests the platform processes.
• Usage data — 25 months from your last recorded activity, or until you object or ask us to erase your data, whichever is earlier. Usage data contains no message content and no names.
• Records of consent choices in the chat widget on this site — 3 years from receipt. A request to erase other data does not erase the record, which is kept as evidence of consent (GDPR art. 17(3)(e)).
• Tax records — our book of turnover, our invoices to Paddle and the related bank statements are kept for 5 years from the end of the year to which they relate (Law on Personal Income Tax, art. 48), and longer only while the tax authority may still assess tax for that year (Law on Tax Procedure and Tax Administration, arts. 114–114ž).
• Audience measurement on this site — event-level data for 2 months in Google Analytics; the cookies it sets expire as described in the Cookie Policy. Page-speed measurements — individual measurements for 7 days, then aggregated statistics in Cloudflare Web Analytics.
• Settings, account and AI configuration audit trails — 90 days; changes to contact retention policies and legal holds on contacts — 7 years.
• Records of data-protection requests, data exports and workspace deletions — 7 years. A record of a workspace deletion holds the workspace name and counts of what was deleted.

AI processing and redaction of personal data

AI features, including replies, the AI assistant for your team, translation, conversation summaries and knowledge-base search, use large language models accessed through OpenRouter, which we engage as a subprocessor under a data processing agreement. Our OpenRouter account is configured to route requests only to the upstream providers named on the subprocessors page, in the regions stated there; they act as its subprocessors. Email addresses, phone numbers, card numbers and IP addresses detected in content sent to AI models are removed before it is sent. Contact details that a workspace publishes for its customers in its knowledge base are not removed. Images that customers send in conversations answered by AI replies are sent to an AI model as they are to produce a text description of what they show, which is stored with the image and deleted together with it; the removal applies to text, including that description. Voice messages that customers send in such conversations are sent to a speech recognition model, only through providers that do not retain them, to produce a transcript, which is stored with the recording and deleted together with it; the removal applies to the transcript. Videos that customers send in such conversations are sent to an AI model, only through providers that do not retain them, to produce a description of what is shown and a transcript of what is said, which is stored with the video and deleted together with it; the removal applies to that text. The text of documents that customers send in such conversations is extracted on our servers, without sending the file to anyone; a scanned document that contains no text is instead sent to an AI model, only through providers that do not retain it, to recognize its text. The text is stored with the document and deleted together with it; it is sent to AI models as text, to which the removal applies. The AI features answer support questions and hand conversations over to a person. They are not designed to make decisions based solely on automated processing that produce legal effects or similarly significantly affect people, and we do not use them to make such decisions about you or to profile people.

Subprocessors

The providers that process personal data on our behalf are listed on the subprocessors page, together with the service each provides and the place where it processes data. Changes to the subprocessors that process data under our Data Processing Agreement are announced to workspace owners in advance, and owners can object to them, as that agreement sets out.

Data location and international transfers

We are established in the Republic of Serbia and operate the service from there. Workspace and conversation data is stored with cloud infrastructure providers that we engage as subprocessors, and AI replies are generated by large language model providers. Personal data is therefore transferred to and processed in countries other than the Republic of Serbia, including countries outside the EEA. Each provider and the place where it processes data are listed on the subprocessors page.

There is no European Commission adequacy decision for the Republic of Serbia, and some of the countries to which personal data is transferred do not have one either. Where we act as your processor and the GDPR applies, transfers to us are governed by the European Commission’s Standard Contractual Clauses, which are incorporated into our Data Processing Agreement; we have carried out a transfer impact assessment for these transfers. Where we act as controller — for your account, billing and this website — we are subject to the GDPR under article 3(2) and have appointed a representative under article 27. Our onward transfers to providers outside the EEA rely on an adequacy decision or on the European Commission’s standard contractual clauses. Under Serbia’s Law on Personal Data Protection, the EEA states and the United Kingdom are on the Government’s list of countries ensuring an adequate level of protection (art. 64); transfers to other countries are made under the contractual clauses in each provider’s data processing agreement, as stated for each provider on the subprocessors page. You can obtain a copy of the relevant safeguards by writing to privacy@trusend.ai.

Cookies and browser storage

We do not use advertising networks or cross-site tracking on this site. Audience measurement on this site uses Google Analytics, loaded through Google Tag Manager and provided by Google Ireland Limited as our processor, and page-speed measurement uses Cloudflare Web Analytics, provided by Cloudflare, Inc. as our processor. Neither is loaded until you accept audience measurement in the banner shown on your first visit; Cookie settings at the bottom of every page lets you change that choice at any time. If you accept chat storage, the chat widget keeps your conversation in your browser between visits. Other information stored in your browser is listed in the Cookie Policy.

Inside the TruSend app, error monitoring and product analytics that run in your browser start only after you accept them in the app’s own banner. You can withdraw that choice at any time in Settings → Profile → Privacy & Data. The analytics keeps nothing on your device.

Whether you are required to provide personal data

Providing account data — your name, email address and workspace name — is necessary to conclude and perform our contract; without it we cannot open an account or provide the service. Providing any other personal data is voluntary. Analytics that run in your browser are based on your consent, and the usage data our servers record is based on our legitimate interests, to which you can object. Declining consent or objecting does not affect your use of the service. You are under no statutory obligation to provide personal data to us.

Your rights

Subject to the conditions set by law, you have the right to access your personal data, to have it rectified or erased, to restrict its processing, to receive it in a portable format, to object to its processing and to withdraw your consent at any time. Many of these actions are available in your workspace; otherwise, write to privacy@trusend.ai. We process personal data in accordance with Serbia’s Law on Personal Data Protection and, where it applies, the EU General Data Protection Regulation (GDPR). We respond to requests within 30 days under Serbian law and within one month under the GDPR. These periods can be extended where the law allows, in which case we inform you of the extension and the reasons for it.

Your right to object. Where we rely on legitimate interests — for usage data and for keeping the service secure — you have the right to object at any time by writing to privacy@trusend.ai. For usage data, once we receive your objection we stop recording it for your account and delete the usage data already recorded; you do not need to give reasons. For processing to keep the service secure, we will stop unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed to establish, exercise or defend legal claims.

You can raise any concern with us at privacy@trusend.ai. You also have the right to lodge a complaint with a supervisory authority: in Serbia, the Commissioner for Information of Public Importance and Personal Data Protection; in the EEA, the supervisory authority of the member state where you habitually reside, where you work or where the alleged infringement took place.

Deleting your data

If you contacted a business that uses TruSend, including through Facebook Messenger, Instagram, WhatsApp or Telegram, that business controls your data. Ask it to delete your data; it can do so in its workspace. You can also write to privacy@trusend.ai and we will pass your request to that business where we can identify it. If you have a TruSend account, you can delete it in Settings → Profile → Privacy & Data. If you are the only owner of a workspace, first make another member an owner, or delete the whole workspace, which deletes your account with it. A workspace owner can delete the whole workspace in the workspace settings; deletion then follows How long we keep it.

Changes

We may update this policy; the date of the current version is shown at the top of this page. If we make a material change, we will notify workspace owners by email or in the app before the change takes effect.