Draft. This policy is being reviewed and is not final yet.
Who we are
Recapi is run by [OWNER: legal entity name], [OWNER: address], [OWNER: company number]. For anything about your data, write to hello@recapi.io.
Two kinds of data
Your account data. When you ask for early access, sign up or pay, we decide what is collected and why: we are the controller.
Your visitors' data. When your site sends us what its visitors do, you decide what is sent and why: you are the controller, and we process it only on your instructions, under a data processing agreement we sign with you.
Your account data
| What | Why |
|---|---|
| Your email address and company name | To create your account, log you in and send you the emails you asked for (early access, invitations). |
| Billing details: organization name, billing email, monthly usage | To invoice you once you add a card. Your card itself is entered on Stripe's page and never reaches us. |
| What you do in the dashboard (keys created, settings changed) | To keep an audit log of your account, for your security. |
We keep account data while your account is open and [OWNER: how long after it closes, e.g. invoices for the legal period].
Your visitors' data
All of it is pseudonymous: we never receive your visitors' names, postal addresses, phone numbers or payment details.
- Ids: your id for a logged-in visitor, or a random id our script keeps in the visitor's browser. Ids must not be email addresses or names.
- Activity: which item a visitor viewed, put in the cart, bought, liked or rejected, and when.
- Recommendations shown: which items we showed, where, and which experiment group the visitor was in.
- Network data: the visitor's IP address and browser headers reach our servers with each request; we store neither.
Our script stores nothing on your visitors' devices until they consent, and respects Do Not Track and Global Privacy Control. Erasing one visitor's data takes a single call to our API. We keep your visitors' data [OWNER: retention period] and delete it when you close your account.
Cookies on this website
recapi.io sets only the cookies it needs to log you in. It uses no advertising or analytics trackers and loads nothing from third parties.
Where your data is stored
On our servers at Hetzner in Germany and Finland, with encrypted backups there too. The companies that help us run Recapi (the full list, with what each one sees: our subprocessors):
| Who | What for | Where |
|---|---|---|
| Hetzner Online GmbH | Hosting and backups | Germany and Finland |
| Cloudflare, Inc. | DNS, and the network in front of the API when it runs on several servers | Global network: a request is decrypted at the location nearest the visitor, which may be outside the EU |
| Amazon Web Services (Amazon SES) | Sending our emails | Frankfurt, Germany |
| Stripe Payments Europe, Ltd. | Billing | [OWNER] |
We tell customers at least 30 days before we add or replace one of these.
Your rights
You can ask to see, correct, export or erase your data, or object to how we use it. Write to us and we answer within one month. If a visitor of your site asks us, we pass the request on to you. You can also complain to your data protection authority, [OWNER: our lead authority].
Changes
When this policy changes, we update this page and, for changes that matter, tell you by email first.
Last updated: [OWNER: date].