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Legal

Privacy Policy

This privacy policy provides information about the type, scope and purpose of the processing of personal data when using our website and services.

Last updated: October 26, 2026 GDPR compliant Servers in the EU
Table of Contents

👤1. Data Controller

The controller within the meaning of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union, and other data protection provisions is:

Alpheris
Owner: Asmir Kuljancic
Vordere Karlstr. 74
73033 Göppingen
Germany

Email: [email protected]
Website: https://alpheris.com

ℹ️2. General Information on Data Processing

The protection of personal data is of great importance to us. We process personal data exclusively in accordance with applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).

Personal data refers to any information relating to an identified or identifiable natural person.

The processing of personal data generally occurs only insofar as it is necessary for the provision of a functional website and our digital services.

Role as a processor: Insofar as we process personal data in the context of the chatbot and SaaS services operated by a merchant (in particular chat messages, leads as well as inbox and email contents of the merchant's end customers), we act as a processor within the meaning of Art. 28 GDPR. The respective merchant is the controller for this data; the processing is carried out exclusively on the merchant's instructions and on the basis of a data processing agreement. For the processing in connection with this website as well as our own account and billing data, we are the controller ourselves (see Section 1).

⚖️3. Legal Bases of Processing

The processing of personal data is carried out on the basis of the following legal grounds:

🌐4. Data Collection When Visiting Our Website

When you visit our website, information is automatically collected by our IT systems.

In particular, the following data may be collected:

This data is stored in so-called server log files.

The processing serves to ensure the smooth operation of the website, technical monitoring, IT security, and abuse prevention. The legal basis is Art. 6(1)(f) GDPR.

🖥️5. Hosting and Infrastructure

Our platform, database and backups are operated on servers within the European Union. Hosting and the database are provided by Hetzner Online GmbH (Nuremberg data center, Germany); backups are stored on a Hetzner Storage Box within the EU.

We use the following infrastructure service providers in particular:

ProviderPurposeLocation
Hetzner Online GmbHHosting, database and backup (Storage Box)Germany / EU
Cloudflare, Inc.DNS, CDN, proxy and DDoS protectionUSA / Global
Microsoft (Microsoft 365 / Graph)Email delivery (primary) and Sign in with Microsoft (optional)EU data centers / US-based company
Apple Inc.Sign in with Apple (optional) and delivery of push notifications to Apple devicesUSA
Google LLCSign in with Google (optional) and delivery of push notifications to Android and Chrome devicesUSA

Signing in via Apple, Google or Microsoft is optional – you can always register with an e-mail address and a password. If you use one of these services, we receive a user identifier and your e-mail address from it; the provider learns that a sign-in with us took place.

Where Apple issues us a token when you sign in with Apple, we store it encrypted and revoke it with Apple when you delete your Alpheris account. You can also remove the link at any time in your Apple ID settings under “Sign in with Apple”.

We only send push notifications to devices where they have been explicitly enabled. For technical reasons, delivery goes through the push service of the respective device manufacturer (Apple or Google); the device identifier and the notification content are transmitted. You can withdraw this at any time on the device or in your account settings.

Data processing agreements pursuant to Art. 28 GDPR are in place with all service providers acting as processors. Insofar as a transfer to third countries (USA) takes place, it is safeguarded in accordance with Section 15.

🧾6. Registration and User Account

A user account may be required to use our platform.

The following data may be processed in this context:

This data is processed for the administration of the user account and for the provision of our services. The legal basis is Art. 6(1)(b) GDPR. We send account and billing emails (such as confirmation codes, invoices and trial notices) through Microsoft 365 (section 5); the legal basis is likewise Art. 6(1)(b) GDPR.

Free trial. The 14-day free trial is available once per person – even if you create further workspaces or install the Shopify app in another store. To check this, we store which workspace your account used the trial for, together with a hash of your email address formed with a secret key (not the address itself). The legal basis is our legitimate interest in preventing misuse of the trial (Art. 6(1)(f) GDPR).

Deleting the account. The owner can delete the account at any time under Account → Security (“Delete account & all data”, with a confirmation code sent by email). We then end running subscriptions, disconnect connected channels (Shopify app, Instagram, WhatsApp), revoke Gmail access with Google and immediately delete all data of the shop – including connected mailboxes, stored emails, chats, contacts, the knowledge base and the AI data derived from them – as well as the user accounts that do not belong to another shop. Only a pseudonymized marker (hash values of the email address and IP address) against repeated use of the free trial remains, together with the billing records at Stripe, which Stripe keeps as an independent controller (section 14). Backups are deleted locally after 14 days and on the encrypted backup storage (Hetzner Storage Box, Germany) after 30 days at the latest.

☁️7. Use of Our SaaS Platform

When using our platform, additional personal data may be processed, in particular:

This data is processed for the provision of the platform, generation of automated responses, improvement of our services, error analysis, and ensuring system security.

🔌8. Use of Our API

Our services can be accessed via application programming interfaces (APIs).

When using the API, the following data may be processed in particular:

This data is processed for the provision of the API and to ensure system security.

🤖9. Chatbot and AI Processing

9.1 Processing of Chat Messages

In the course of usage, the following data may be processed:

This data is processed exclusively for the provision of the chatbot functionality.

Typing preview in live chat. If the shop uses the Business or Enterprise plan, the text you enter in the chat field is transmitted to the shop while you are typing and may be shown to the shop's staff in the live chat so they can reply faster. This only happens if you have consented to the chat. The preview is cached for no more than 8 seconds and is not stored permanently; only the message you actually send is stored. On other plans only the fact that you are typing is transmitted, not the text. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in handling your request quickly).

Visitor number and city in live chat. So the shop can tell visitors without a name apart in the live chat, we assign a running number per visitor ID and determine the approximate city from the IP address while you chat (e.g. “Visitor 013 from Vienna”). We determine the city with a location database on our own server (IP Geolocation by DB-IP); the IP address is neither transmitted to third parties nor stored for this – only the number, city and country are stored. If the same visitor returns, the chat recognises them by their visitor ID. As soon as you provide your name, it is shown instead. The legal basis is Art. 6(1)(f) GDPR (the shop's legitimate interest in handling enquiries in an orderly way).

9.2 Use of Artificial Intelligence

We use so-called Large Language Models (LLMs) to generate automated responses. The AI providers used are Anthropic, PBC (USA), OpenAI (USA) and Mistral AI (France, EU). Through Anthropic (AI model Claude) we in particular write chat and email responses and check them before they are sent, describe images in customer requests and evaluate conversations for the merchant. If Anthropic is unavailable or overloaded, OpenAI (AI model GPT) takes over these tasks, followed by Mistral AI. Through Mistral AI we also convert text into vector representations (embeddings) and process uploaded documents via optical character recognition (OCR) and, where applicable, audio content via transcription. For incoming emails, the AI first checks, based on the sender address, subject and text, whether the message needs a reply; if it skips an email, it gives a short reason (such as newsletter or invoice).

The following applies:

Learning from answered requests. This is different from our system learning from requests that have already been answered: question and answer are stored as an example in the knowledge base of the respective shop so that similar questions are answered more consistently in future. No AI model is trained or changed in the process. The examples apply only to that shop, are not passed on to third parties and are deleted together with the shop's data. The feature is active by default; individual answers are not approved one by one. Learning happens when a case is closed and only from cases that were solved well: for this, the conversation, after contact details and identifiers have been replaced with placeholders, is sent to our AI providers (see above), which phrase question and answer in general terms and without names, addresses, dates, order, customer or phone numbers. If that is not reliably possible, nothing is learned; cases involving special categories of personal data (Art. 9 GDPR, such as health information) are never learned. The learned entry is anonymous and contains no reference to the original conversation; a review note linking the two is deleted after 30 days, and so is a learned entry that has not come up again for one year. Learning only uses conversations that started after learning was turned on for the channel concerned. The shop operator sees the learned answers in the inbox under Settings → Learned answers and can delete them there. They can turn learning off per channel (emails, live chats, WhatsApp and Instagram) at any time in the dashboard under AI → Learning. By default, answers learned from emails are only used by the AI assistant for that shop’s email replies. The shop’s website chatbot, whose answers are visible to website visitors, only uses them once the shop operator turns on “Use learned answers in the website chatbot”; even then, only content in which no personal data can be recognised after replacement is used.

Comparison with earlier answers from the team. Before the AI assistant rates an email reply as confident, it compares its draft with answers the shop’s staff sent to similar questions in the last 90 days. For this, the new request, the draft and up to three earlier questions with their answers from the same shop are sent to one of our AI service providers (see above) after contact details and identifiers have been replaced with placeholders. Nothing additional is stored and no AI model is trained; answers from other shops are never used. The shop operator can turn the comparison off in the dashboard under Mail Agent → Details.

For emails answered through our inbox, we store the sent reply with the conversation and, if an AI draft was used, that draft as well. Learning only uses what an employee changed in the draft or wrote themselves – under the same rules as above. This data is deleted together with the conversation, including when the mailbox is disconnected.

Learned procedures. In addition, our system can derive from requests that a member of the shop’s team resolved (live chats and emails answered through our inbox or from a connected Outlook or IMAP mailbox) how the team handles a certain type of request: how to recognise it, which details the team needs from the customer, which steps it takes and how the case ends. For this, the case’s messages are sent to our AI providers (see above) after recognisable personal data has been removed (names, contact details, addresses, order and customer numbers are replaced with placeholders); the result is cleaned again and only stored if it contains no such data. For each shop we store the procedure without reference to individual customers, how often it occurred, which team members worked on it, and for each case an irreversible key so that a case is not counted twice. No AI model is trained or changed in the process. Cases involving special categories of personal data (Art. 9 GDPR, such as health information) and data we receive via the Gmail API are not used. Learning only uses conversations that started after the shop operator turned the feature on (on by default, can be turned off per channel in the dashboard under AI). A procedure is used once two matching cases have occurred; if it contradicts the shop’s knowledge base, the knowledge base applies. The chatbot only mentions a procedure’s internal steps and outcome to customers if the shop operator allows this for that procedure. The shop operator can view, edit, pause and delete every procedure in the knowledge base. The legal basis is processing on behalf of the shop operator (Art. 28 GDPR) based on their legitimate interest in handling requests consistently and quickly (Art. 6(1)(f) GDPR). When a conversation is deleted, we also remove its key; a procedure that has not occurred again for one year is deleted, and all of a shop’s procedures are deleted together with its data.

Automatic distribution of requests to team members. Merchants can have incoming tickets and live chats distributed to their team members automatically. For this we send a short version of the request (subject or the latest customer messages, with contact details such as email addresses and phone numbers filtered out beforehand) together with information about the team members – internal ID number, role, assigned topics, number of open requests and whether they are currently reachable, without names or email addresses – to the AI provider (see above), which suggests the right person; the decision and a short reason are stored with the ticket and shown to the merchant's team. So that the distribution fits the team, we record when a team member assigns or reassigns a request by hand: a short description of the request (subject, category or topic, at most 160 characters, contact details and order numbers filtered out; for live chats without a subject a filtered excerpt of at most 90 characters), the channel, the chosen and the previously responsible person and the time. We keep at most the latest 200 entries per shop and for at most 365 days; they are deleted when the team member is removed and together with the account or shop. We act on behalf of the merchant; the legal basis is the merchant's legitimate interest in handling requests promptly (Art. 6(1)(f) GDPR). The distribution only decides who works on a request – it has no legal effect on customers or team members, and every assignment can be changed by hand at any time.

9.3 Transparency Notice pursuant to the EU AI Act

Our services may include systems based on artificial intelligence.

These systems generate content automatically based on user inputs.

The generated content may be incomplete or erroneous and should be verified accordingly.

🛡️10. Abuse Prevention and Security Systems

Automated systems may be used to ensure the integrity and security of our platform and to detect and prevent abusive use.

In particular, the following data may be processed for this purpose:

This processing is based on our legitimate interest pursuant to Art. 6(1)(f) GDPR.

🍪11. Cookies and Similar Technologies

Our website uses cookies and similar technologies.

Cookies are small text files that are stored on the user's device.

We distinguish between the following categories:

Strictly Necessary Cookies

In the Shopify admin we sign you in without a cookie using Shopify’s session token (store and Shopify user ID, valid for about 1 minute). In the browser’s session storage we only keep the store and the admin identifier.

When you install via Shopify, we take the shop owner’s name and the email address Shopify uses to reach you from your shop data. The name appears as the display name in your account unless you have entered your own; we send invoices and notices about your subscription to that address. The legal basis is the performance of a contract (Art. 6(1)(b) GDPR).

Legal basis: Art. 6(1)(f) GDPR

Analytics Cookies

These cookies are used for the statistical analysis of our website usage.

Legal basis: Art. 6(1)(a) GDPR (consent).

Marketing Cookies

These cookies enable personalised advertising on other platforms and measure campaign performance.

Legal basis: Art. 6(1)(a) GDPR (consent).

Personalisation Cookies

These cookies remember preferences such as region or presentation beyond what is strictly necessary.

Legal basis: Art. 6(1)(a) GDPR (consent).

As of today we set no cookies in these three categories. The choice is still offered in the consent banner so that your decision is already on record should we introduce such a tool in the future.

We store your choice – including a refusal (“Essential only”) – in the strictly necessary cookie alpheris_cookie_consent so the banner does not reappear on every visit (retention: 180 days; content: version, categories, timestamp).

Storage by the chat assistant

The chat assistant on this website stores data in your browser’s storage (localStorage and sessionStorage). This is not a cookie in the narrow sense, but § 25 TDDDG treats it the same way. We distinguish two kinds.

Needed for the chat. The assistant stores the following without separate consent, because the chat you are using does not work without it:

Legal basis: § 25(2) no. 2 TDDDG (strictly necessary for the chat you requested) and Art. 6(1)(b) GDPR where your enquiry relates to a contract, otherwise Art. 6(1)(f) GDPR (answering your enquiry).

Notices without storage. If you have neither accepted nor declined in the consent banner, or the website shows no banner the assistant recognises, it may still offer general notices that only need the page you currently have open – for example when you spend a while on a product, shipping or FAQ page, the search finds nothing, or you don’t continue in the cart. For these the assistant reads and stores nothing in your browser and sends nothing to our server; what it remembers (such as that a notice has already appeared) stays only in the memory of the open page and is gone when you reload. Only when you tap a notice does the chat open, and it is then processed like any other chat message. If you declined in the banner, the assistant shows no notices on its own.

Only with your consent. The following functions only run if you have consented via the website’s consent banner and the assistant recognises that consent. Without consent they stay off; the chat itself still works.

In online shops with a cart, the chat assistant reads the shop’s cart in your browser (products, variants, quantities, total) to show helpful notices, for example when a variant in your cart has sold out. For these notices the cart stays in your browser. Only for size help do we send the product and the two sizes to our server, which only checks whether the shop provides a size chart and does not store this information. Likewise, for tips about a single product (such as “Not sure about the size?” or questions about care and use) we only send the product’s name and address and whether it comes in several sizes to our server, which only checks whether the shop provides suitable information for this product; nothing is stored. Some tips offer topics to tap (such as “Material & care” or “Shipping”); which ones also depends only on the shop’s information. If you tap a topic, the matching question is sent to the chat as your message and processed like any other chat message. Which of these tips a shop can show at all depends on its product range and the information on its website, not on your behaviour. When the assistant reminds you of an abandoned cart, it sends the product name and the cart value to our server as an event so the shop can evaluate its reminders.

Also only with consent, the assistant sends events such as viewed products, items added to the cart and the start of checkout to our server so the shop can evaluate its notices.

Legal basis: Art. 6(1)(a) GDPR together with § 25(1) TDDDG (consent). You can withdraw your consent at any time in the consent banner; if you decline there, the assistant deletes this data from your browser. Alternatively, you can clear site data for this domain in your browser.

Cloudflare Turnstile (protection of our forms)

Our contact and enquiry forms are protected against automated submissions by Cloudflare Turnstile. When you open a protected form, a script is loaded from challenges.cloudflare.com. Cloudflare processes your IP address and technical characteristics of your browser in order to assess whether the request comes from a human.

The provider is Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. According to the provider, Turnstile does not set cookies for advertising purposes. A transfer to the USA cannot be ruled out; it is based on the Standard Contractual Clauses.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in protection against abuse and spam.

Contact and enquiry forms

When you write to us through a form on this website, we process the details you enter — depending on the form: name, email address, company, shop address, phone number and your message — along with the time of submission and your IP address. We use these details solely to answer your enquiry.

Legal basis: Art. 6(1)(b) GDPR where your enquiry is aimed at a contract, otherwise Art. 6(1)(f) GDPR (responding to enquiries). We delete enquiries once they have been dealt with conclusively and no statutory retention periods apply.

You can change or withdraw your decision at any time using the "Cookie settings" link in the site footer.

📈12. Analytics Tools

Optional analytics tools are loaded only if you actively allow analytics cookies.

Currently, no optional tracking or marketing scripts are enabled by default.

If we use analytics tooling, we prefer privacy-friendly options, such as:

Further information: https://plausible.io

🔗13. Recipients and Third-Party Services

Our website may integrate content or services from third-party providers, for example:

Data is only transferred when users actively interact with such content.

13.1 Recipients and Sub-Processors

To provide our services, we use carefully selected service providers who, as sub-processors, act exclusively on our instructions or on the instructions of the respective merchant. These include in particular:

RecipientPurposeLocation
Hetzner Online GmbHHosting, database, backupGermany / EU
Anthropic, PBCAI processing (responses, checks, image descriptions, evaluations)USA (EU Standard Contractual Clauses)
OpenAIAI processing as a fallback and for load balancing (responses, checks, image descriptions, evaluations) and as an independent second check of answers before they are sentUSA (EU Standard Contractual Clauses)
Mistral AIAI processing (responses, embeddings, OCR, transcription)France (EU)
Microsoft (Microsoft 365 / Graph)Email delivery (primary)EU data centers / US-based company
Cloudflare, Inc.DNS, CDN, proxy, DDoS protectionUSA / Global
Stripe, Inc.Payment and billing processing (see Section 14)USA

13.2 Optional Integrations Activated by the Merchant

Depending on the configuration chosen by the respective merchant, the following integrations may additionally be activated, through which personal data is transferred to or retrieved from the listed providers:

Which data we receive from Meta through an Instagram or WhatsApp connection, and how to have it deleted, is explained under Data deletion. If a person requests deletion of their data through Meta, we immediately disconnect the channel connection we can attribute to their Meta ID and delete its access tokens and identifiers; the messages in the merchant's inbox remain, because the merchant as controller decides about them, and are deleted through the merchant.

Instagram and WhatsApp (Meta). When a merchant connects their Instagram account or WhatsApp number, we receive and send their customers’ messages through Meta’s interfaces on the merchant’s behalf. We process message contents (including images, videos and voice messages), profile name or username, the address of the Instagram profile picture (we delete it after 4 days), for WhatsApp the phone number, as well as timestamps and delivery status. The purpose is answering the merchant’s customer enquiries. We act as the merchant’s processor; the legal basis is their contract with you or steps prior to entering into it (Art. 6(1)(b) GDPR) or their legitimate interest in answering your enquiry (Art. 6(1)(f) GDPR). The contracting parties are, for Instagram, Meta Platforms Ireland Ltd., which operates Instagram as an independent controller (its privacy policy and terms apply), and, for the WhatsApp Business Cloud API, WhatsApp Ireland Limited, which processes the messages as the merchant’s processor under the WhatsApp Business Data Processing Terms. Meta also transfers data to group companies in the USA, based on the EU-US Data Privacy Framework and the EU Standard Contractual Clauses (section 15). How to request deletion is explained under Data deletion. If the merchant removes Alpheris’s access at Meta and Meta notifies us, we disconnect the connection and delete access tokens and identifiers.

Microsoft Outlook. When a merchant connects an Outlook or Microsoft 365 mailbox, Alpheris accesses it through Microsoft Graph with the permissions Mail.ReadWrite, Mail.Send, for shared mailboxes additionally Mail.ReadWrite.Shared and Mail.Send.Shared, as well as User.Read, offline_access, openid, profile and email – for the same purposes and with the same storage as for Gmail (section 13.3). When the merchant disconnects the mailbox, we delete the access tokens immediately. If they choose “Disconnect and delete all emails”, we also delete the stored emails and the data derived from them immediately. If they choose “Disconnect only”, they remain as a read-only history in their inbox; no new emails arrive and nothing is sent until they delete them or the periods in section 16 apply. The same applies to IMAP mailboxes as to Outlook. There is no automatic revocation with Microsoft, because Microsoft offers no way to do this that affects only Alpheris; the merchant removes access with Microsoft at myaccount.microsoft.com (work or school accounts) or account.live.com/consent/Manage (personal Microsoft accounts), and in organizations the administrator can do so as well.

Deleting in the Alpheris inbox. When a team member deletes an email conversation or a single email in the inbox, it disappears from Alpheris and we delete the copy stored with us. In the merchant's mailbox (Gmail, Outlook, IMAP) the email stays unchanged – Alpheris deletes nothing there. As long as it remains there, it may be cached briefly when the mailbox is synchronized, but it is no longer shown. So that it does not reappear, we only keep its technical identifier and the time of deletion (without content); these markers are deleted at the latest together with the account. If the customer later writes again in the same conversation, the conversation reappears.

Shopify. When a merchant installs the Alpheris app in their Shopify store, we receive, on the merchant's behalf through the Shopify API, read access to products, orders, customers, inventory, shipping settings, markets (countries, currencies and shipping options per market), store content (pages, blog posts, metaobjects), the store’s legal policies (terms, refund, shipping, privacy), discounts and returns, as well as write access to orders (for example to change the shipping address) and to returns. The chat widget appears in the store through the Alpheris theme app extension, which the merchant turns on in the theme editor; this requires no write access. The purpose is answering order, delivery and product questions in the chat and the inbox, building the knowledge base and the optional import of the customer base into the inbox. When the merchant uninstalls the app, we delete the Shopify access immediately; we delete the store's remaining data – including connected mailboxes and their stored emails – as soon as Shopify sends the deletion request (48 hours after uninstalling). Deletion requests for individual customers are carried out immediately; data requests for individual customers are logged, and we provide the merchant with an overview of the data stored about that person on request.

Your order in the chat (Shopify). If a merchant has turned this on and you are signed in to their Shopify store with your customer account, the chat assistant shows your latest order when you open the chat. You are recognised exclusively through Shopify: the chat asks the store, Shopify forwards the request to us with your customer number and a signature, and we verify this signature before retrieving your orders from Shopify. Only status, product, size or variant, order number and date are shown (plus, where available, the expected delivery date, the tracking link and a return deadline documented by the store) – never your address, payment details or prices. At most your last three orders are retrieved, and only when you open the chat; if the store requires consent for the chat, only after you have given it. We do not store this information; it stays in our server's memory for at most one minute so that opening the chat again does not query Shopify again. Using “Not you?” you can hide the card on this device or sign out of the store. We act on the merchant's behalf; the legal basis is the merchant's contract with you (Art. 6(1)(b) GDPR) or their legitimate interest in giving you quick information about your order (Art. 6(1)(f) GDPR).

Your order by email (Shopify). If you ask about your order by email without giving an order number, the AI can retrieve from Shopify the most recent orders (at most three) placed under your sender address and tell you their order number, date, shipping status, tracking and – where Shopify reports it – the expected delivery date. This only happens if your email provider has confirmed that the message really comes from your address or domain (DMARC or a matching DKIM signature). For this we read the verification result from your email's header (“Authentication-Results”) and store it with the message. Orders of other addresses, your postal address and payment details are not used; this lookup does not take place in the website chat. If one of the merchant's staff members names an order number or email address while drafting a reply, the AI retrieves that order from Shopify as well. We record every lookup with the time, a shortened email address, the number of results and, where applicable, the staff member's ID for as long as the conversation is stored. We act on the merchant's behalf; the legal basis is the merchant's contract with you (Art. 6(1)(b) GDPR) or their legitimate interest in giving you quick information about your order (Art. 6(1)(f) GDPR).

Insofar as a transfer to third countries takes place via these recipients, the information in Section 15 applies.

Connected tools (chat and email). If a merchant connects tools – such as appointment booking (Calendly, Cal.com, Acuity, Google or Outlook Calendar), payment and invoicing services (Stripe, Mollie, PayPal, Square, Invoice Ninja, Billomat), their shop system or shipping services (WooCommerce, Shopware, Magento, Sendcloud, DHL, UPS, AfterShip), a status page, their own interface (“Custom action”) or an MCP server –, the AI can look up information there in the chat and for emails. For this we transmit the details from your message that are needed to the merchant’s system or to the named provider, such as the order or invoice number and your email address. The AI only gives order and invoice details once you have identified yourself: in the chat with the email address or phone number of the order, by email solely through the sender address you are writing from. Whether the AI may change anything in the merchant’s system (for example cancel an order or change an address) is decided by the merchant; by default it only prepares this, and it is carried out only when a staff member sends the reply. We record that such an action was prepared, carried out or discarded, with the time, the tool and the person who triggered it; the details (such as the order number or new address) are deleted as soon as the action is done or discarded, and after 14 days at the latest. We store the tools’ answers only as part of the conversation. We act on behalf of the merchant; the legal basis is their contract with you (Art. 6(1)(b) GDPR). In Shopify stores the AI does not use payment or invoicing services; payment there runs exclusively through the Shopify checkout.

Copies of shipping confirmations. If a merchant sets up “Shipping email copy”, their store sends us a copy of its shipping confirmations to an address created only for them (received via Cloudflare Email Routing). We only process emails from the one sender the merchant has approved via a confirmation link and whose mail server confirms the origin; all others are discarded. From the email we store the order number, your email address as recipient, carrier, tracking number, subject and time – we do not store the email itself. The AI uses this to answer questions about your parcel, and only if you identify yourself with the order’s email address. We act on behalf of the merchant; the legal basis is their contract with you (Art. 6(1)(b) GDPR) or their legitimate interest in quick information (Art. 6(1)(f) GDPR). We delete the data after 90 days, or immediately when the merchant disconnects.

Tenant lists of property managers. If a property manager uploads its tenant list (name, email address, phone, property, unit, role as tenant or owner), we store it on its behalf. It is used only to match an incoming email to the right person and unit by the sender address, so the reply fits without asking again, and in the manager's inbox. The list is never used in the website chat. The manager can replace or delete the list at any time; deleting removes all entries. The legal basis is the data processing agreement with the manager (Art. 28 GDPR).

Help articles and documentation as knowledge. When a merchant connects GitBook, Confluence, a Zendesk Help Center or an Intercom Help Center, we use their access (stored encrypted with us) to retrieve the published articles or pages – when connecting and once a day after that – and store their text in the merchant’s knowledge base so the AI can answer questions from it. We only read there; we do not retrieve tickets, contacts or customer data through this connection. We process personal data only insofar as it appears in the articles themselves (for example the name of a contact person). The providers GitBook, Atlassian (Confluence), Zendesk and Intercom may also process data in the USA. When the merchant disconnects, we delete the access and the imported articles immediately. We act on the merchant’s behalf (Art. 28 GDPR).

Files sent by the AI (chat, email, WhatsApp, Instagram). If you explicitly ask for a specific document, the AI can send you exactly that document – never on its own initiative and at most one per reply. This covers files the merchant has released for this purpose in their knowledge base (such as a size chart, manual, data sheet or withdrawal form), PDF files publicly available on their website, and your invoice as a PDF. We retrieve the invoice from the merchant's connected invoicing service (Stripe, Mollie, Invoice Ninja or Billomat) and only send it after the same verification as above: in the chat with the invoice number and the email address or phone number on the invoice, by email only to the sender address you are writing from. The file is sent to you as an attachment to the reply; for WhatsApp and Instagram we transmit it to Meta Platforms for this purpose, for Instagram via a signed link that opens only this one file and expires after one hour. The AI does not send knowledge base files that have not been released. We store the file together with the reply as part of the conversation so that the merchant's team can see what was sent, and delete it together with the conversation. We act on behalf of the merchant; the legal basis is their contract with you (Art. 6(1)(b) GDPR) and, for general documents without a contractual context, their legitimate interest in answering your request (Art. 6(1)(f) GDPR).

Forwarding to the merchant's tools (CRM, helpdesk, newsletter, analytics, tasks, notifications, webhooks). If a merchant connects one of the following tools, we transmit data to the merchant's account with that provider on the merchant's behalf when certain events occur:

We act as the merchant's processor. The merchant, as controller, decides which tools to connect and needs a legal basis of their own, usually your consent for newsletters and analytics. The providers are independent controllers or processors of the merchant and are partly located in the USA (section 15). We store access keys encrypted and delete them when the merchant disconnects the tool.

Company logos in the inbox. When a company writes to a connected mailbox, the inbox shows its logo instead of initials – but only if the company itself has published it in the DNS of its domain (a BIMI record with a mark certificate and DMARC protection). For this, our server only looks up the domain name of the sender address (for example shopify.com) in the DNS and loads the logo named there from the company's address. No email addresses, names, content or user data are transmitted; no lookup is made for addresses at consumer email providers (such as gmail.com, gmx.de, web.de). We store the logos on our servers in Germany (Hetzner) for at most 30 days, and the finding "no logo available" for at most 7 days. Users' browsers load them only from Alpheris, never directly from the company.

13.3 Use of Google user data (Gmail)

When a merchant connects a Gmail account in Alpheris under “Connect a channel” (“Connect Gmail”) and then confirms access with Google, Alpheris accesses that mailbox through the Gmail API with the following scopes:

ScopeWhat we use it for
gmail.modifyreading emails and attachments to show customer requests in the Alpheris inbox; marking emails as read and starring them
gmail.sendsending replies on the merchant's behalf, written by the merchant or by a reply assistant the merchant has enabled
openid, email, profileidentifying and displaying the connected Gmail address and mailbox name

Purpose. We use this data solely to provide the features the merchant enables: showing incoming customer emails in the Alpheris inbox, generating reply suggestions, sending replies on the merchant's behalf, and categorizing requests in Alpheris and marking them as handled. We do not use it for anything else.

AI processing. To generate reply suggestions and categorize requests, the content of individual emails is sent to our AI providers Anthropic, PBC (USA), OpenAI (USA, as a fallback) and Mistral AI (France, EU). For categorization, the subject lines of other emails from the same sender to the same merchant are added (at most eight, without their content), so that, for example, an order number already given there is not asked for again; order numbers and other identifiers are replaced by placeholders before transmission. Neither Anthropic nor OpenAI nor Mistral AI nor we use Google user data to train, develop or improve generalized AI or machine-learning models. Reply patterns derived from answered emails (section 9.2) are used only for the same merchant's account and are never shared with other merchants. We do not derive learned procedures (section 9.2) from data we receive via the Gmail API.

No sharing. Google user data is never sold, never used for advertising (including personalized or retargeted advertising) and never transferred to third parties, except to the service providers listed in sections 5 and 13.1 as necessary to provide the features, where required by law, or as part of a merger or acquisition with these commitments preserved.

No human reading. Alpheris staff do not read Google user data unless the merchant has given explicit consent for a specific case (for example in a support request), it is necessary to investigate abuse or for security purposes, or it is required by law. Team members the merchant adds see the emails in the merchant's own inbox.

Storage and deletion. Email content and access tokens are transmitted encrypted and stored on servers in Germany (Hetzner); access tokens are additionally encrypted. We keep them while the mailbox is connected. When the merchant disconnects the mailbox, we revoke access with Google and immediately delete the access tokens; no new emails are fetched and nothing more is sent. As with other mailboxes (section 13.2), the merchant chooses: with “Disconnect and delete all emails” we also immediately delete the stored emails of that mailbox and the reply suggestions, reply patterns and categorizations derived from them. With “Disconnect only” the emails stored so far remain as a readable history in their inbox until they delete them there or the periods in section 16 apply; they continue to be used only for this display. Anything that cannot be clearly attributed to a mailbox at that point is deleted by a nightly cleanup job promptly, at the latest within 30 days. When the merchant deletes their account, we revoke access with Google and delete all data immediately. Backups are deleted locally after 14 days and on the encrypted backup storage (Hetzner Storage Box, Germany) after 30 days at the latest.

Revoking access. The merchant can revoke access at any time in the Alpheris dashboard under Mail (mailbox menu → “Disconnect mailbox”) or in their Google account at myaccount.google.com/permissions.

Limited Use. Alpheris' 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.

If a merchant instead connects a Gmail account via IMAP with an app password, section 13.2 applies as for other IMAP mailboxes; storage and deletion as for other IMAP mailboxes (section 13.2, including the choice when disconnecting), without revocation with Google, as Alpheris then has no Google access.

💳14. Payment Processing

For the processing of payments, we use payment service providers such as Stripe, Inc.

The following data may be processed:

Stripe processes this data as an independent data controller.

If you install Alpheris via Shopify, Shopify bills the subscription; we only receive plan and subscription status, no payment details.

Further information: https://stripe.com/privacy

🌍15. Data Transfers to Third Countries

A transfer of personal data to countries outside the European Economic Area may occur.

Hosting, database and backups take place within the EU (Hetzner in Germany); the fallback AI Mistral AI processes in France. A transfer to the USA takes place in particular with the following recipients: Anthropic and OpenAI (AI processing of chat and email content), Microsoft (email delivery), Cloudflare (DNS/CDN/proxy), Stripe (payment processing), Google (Sign in with Google and delivery of push notifications to Android and Chrome devices; where activated by the merchant, also Gmail), Apple (Sign in with Apple and delivery of push notifications to Apple devices) and – where activated by the merchant – Meta Platforms (Instagram, WhatsApp; sign-in via Facebook) and Shopify (Canada and USA; for Canada there is an adequacy decision of the European Commission).

Such transfers are carried out exclusively in compliance with the legal requirements pursuant to Art. 44 et seq. GDPR. For this purpose, we use in particular the following mechanisms:

⏱️16. Retention Period

Personal data is only stored for as long as necessary for the respective purpose.

Data TypeRetention Period
Account dataDuration of business relationship + statutory retention periods
Billing data10 years
Chat and conversation datafor as long as the merchant maintains an active relationship with Alpheris – during that time the conversation history is their working tool and the purpose persists; once the relationship ends, the data is deleted automatically after 12 months without further activity. Earlier deletion at any time on the merchant’s instructions; immediately upon deletion of the account.
AI data derived automatically from conversations (memory, examples, detected knowledge gaps)12 months from creation – regardless of the relationship. Knowledge curated and approved by the merchant is not covered by this.
Inbox/email contents from connected mailboxes (Gmail, Outlook, IMAP) including reply suggestions and reply patterns derived from themWhile the mailbox is connected, at most six years from the end of the calendar year of the correspondence in question (statutory commercial and tax retention periods, section 257 HGB, section 147 AO); immediately after disconnecting if the merchant chooses deletion; if they keep the history, the same periods as for connected mailboxes apply until they delete it; immediately when the account is deleted – anything that cannot be clearly attributed to a mailbox at the latest within 30 days; backups see below
Emails deleted in Alpheris (trash)30 days, then permanently deleted automatically; before that they can be permanently deleted at any time, individually or all at once. They remain untouched in the mailbox at the provider.
Leads (name, email, phone)Until the purpose is fulfilled or as instructed by the responsible merchant
Shopify data (products, orders, customers, etc.)While the app is installed; after uninstalling, access deleted immediately, remaining data with Shopify's deletion request (48 hours after uninstalling); individual customers immediately on a deletion request
Data after the account is deletedImmediately (exceptions in section 6)
Backups (encrypted)14 days locally; 30 days at the latest on the backup storage (Hetzner Storage Box, Germany)
Server log files30 days
Login sessions (IP address, browser identifier, device label)for the duration of the session; 90 days after expiry or sign-out so account access remains traceable, then deleted automatically
Support requests6 months
Merchant’s customer records (contacts: name, email address, phone number)six years from the end of the calendar year of the last activity (statutory commercial and tax retention periods), then deleted automatically; immediately when the account is deleted
Address of a customer’s Instagram profile picture4 days

End customers' IP addresses are not stored permanently but are processed only transiently for security purposes and to limit request frequency (rate limiting).

When connected to a Shopify store, we process order, product and customer data from that store on behalf of and under the instructions of the merchant (controller) — in particular to answer order and delivery-status questions, to change the delivery address on an order, and for the optional, one-time import of the existing customer base into the support inbox. Only the data required for the respective purpose is processed.

Insofar as we process data as a processor on behalf of a merchant, this data is deleted or returned at the merchant's choice upon termination of the contractual relationship.

📜17. Rights of Data Subjects

You have the following rights:

To exercise your rights, you may contact us at any time: [email protected]

🏛️18. Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority pursuant to Art. 77 GDPR.

Competent authority:

Der Landesbeauftragte für den Datenschutz Baden-Württemberg
https://www.baden-wuerttemberg.datenschutz.de/

🔒19. Data Security

We implement comprehensive technical and organizational measures pursuant to Art. 32 GDPR to protect personal data.

These include in particular:

📝20. Amendments to This Privacy Policy

We reserve the right to amend this privacy policy to adapt it to changed legal requirements or changes to our services.

The current version is available on our website at all times.

✉️21. Contact

If you have any questions regarding data protection, you may contact us at any time:

Email: [email protected]

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