Privacy Policy

1. Who we are

The service is operated by advixory s.r.o., IČO 55 211 771, with registered seat at Námestie osloboditeľov 3/A, 040 01 Košice – Staré Mesto, Slovak Republic, registered in the Commercial Register of the Municipal Court Košice, section Sro, insert No. 55999/V ("advixory", "Townproof", "we").

For account, billing, website and product-usage data we are the controller. For the contact data that business customers upload and instruct us to process, we act as a processor on that customer's behalf, and the customer is the controller. Privacy contact: [email protected]. See also our Imprint and Cookie Policy.

2. What data we collect

• Account data: name, email address, organization, authentication events (including magic-link sign-in), and settings.
• Contact data uploaded by customers: contact email, normalized email, first name and phone number. This data originates from our customers, who collected it from their own contacts and customers.
• Usage data: product actions, page views, onboarding progress and feature events.
• First-party analytics events: event names, timestamps, URLs, UTM parameters and an anonymous identifier.
• Technical data: IP address and information about the device and browser; for tracked review links, we use a visitor identifier to attribute clicks. Personalized audit or report links contain a pseudonymous recipient identifier used to record that a report was served and attribute campaign response.
• Audit and compliance logs: sends, suppressions, consent events, token actions, billing changes, deletions, the acting user, IP address where needed for compliance, and timestamps.
• Free-audit data from unauthenticated visitors: business name, location, Google Business Profile URL, contact email, competitor information and a hashed IP address.
• Billing data: handled by our Merchant of Record (Polar); we receive limited subscription and invoice metadata.

3. How we use it

• Service delivery: authentication, organization setup, contact import, review-request workflows, unsubscribe and suppression handling, and support.
• Billing: subscription checkout, invoicing, tax handling, plan limits and account administration, performed through Polar as Merchant of Record.
• First-party product analytics: measuring activation, reliability and usage. Where enabled, PostHog is an optional analysis and debugging interface only, never the source of truth for metrics.
• Security and anti-abuse: protecting the service, enforcing send limits and tenant isolation, and preventing fraud and misuse.
• Legal, tax and compliance: consent attestation, data-subject requests, retention, auditability and statutory obligations.
• Optional AI assistance: generating suggested review-reply drafts when, and only when, you use that feature.

4. Legal bases (Article 6 GDPR)

We process account and billing data to perform our contract with you (Article 6(1)(b)).

We process usage, technical, security and first-party analytics data, and we send service-related and B2B communications, on the basis of our legitimate interests in operating, securing, measuring and improving the service (Article 6(1)(f)). We have weighed these interests against your rights, and you may object at any time (see Section 9).

We process audit, billing, accounting, tax and compliance records where required to meet a legal obligation (Article 6(1)(c)).

We rely on consent for non-essential cookies and optional analytics (Article 6(1)(a)); you may withdraw consent at any time.

For the contact data customers upload, the customer is the controller and determines the purposes and legal basis; we process that data only on the customer's documented instructions under our Data Processing Agreement.

5. Children

Townproof is a business product and is not directed to children. In Slovakia the age of consent for information-society services is 16 (§15 of Act No. 18/2018 Coll.). We do not knowingly collect personal data of children under that age.

6. Recipients and sub-processors

We use the sub-processors listed below to provide Townproof. The Data Processing Agreement contains the same list and is kept in sync with this Policy. We may also disclose personal data to professional advisers, or to authorities and courts where required by law. We do not sell personal data and do not use third-party advertising pixels.

• Postmark (AC PM, LLC) — Delivery of review-request and transactional email.
  Location: United States · Transfer safeguard: EU Standard Contractual Clauses; EU–US Data Privacy Framework.
• Polar (Polar Software, Inc.) — Merchant of Record for subscriptions, payments, invoicing and tax. Polar is the seller of record and acts as an independent controller for the payment, billing and tax data of buyers. See Polar's privacy policy at https://polar.sh/legal/privacy-policy.
  Location: United States · Transfer safeguard: EU Standard Contractual Clauses.
• Neon (Neon, Inc.) — Managed PostgreSQL hosting for the primary application database.
  Location: European Union (Frankfurt, Amazon Web Services); United States parent company · Transfer safeguard: Data stored in the EU; EU–US Data Privacy Framework and Standard Contractual Clauses for any parent access.
• Sentry (Functional Software, Inc.) — Error and performance monitoring, configured to scrub personal data; session replay is disabled in production.
  Location: European Union (Frankfurt); United States parent company · Transfer safeguard: Event data stored in the EU; EU–US Data Privacy Framework and Standard Contractual Clauses for any parent access.
• PostHog (PostHog, Inc.) — Optional product analytics and masked, sampled session replay. Disabled by default and only used with consent; Townproof's own database remains the authoritative analytics ledger.
  Location: European Union (Frankfurt) · Transfer safeguard: Data hosted in the EU.
• Google (Google Ireland Limited) — Google Maps and Places lookups for business-profile data, competitor and audit information, and the optional map widget.
  Location: European contracting entity; processing may occur globally · Transfer safeguard: EU–US Data Privacy Framework; EU Standard Contractual Clauses.
• Cloudflare (Cloudflare, Inc.) — Authoritative DNS for Townproof's domains.
  Location: United States · Transfer safeguard: EU–US Data Privacy Framework; EU Standard Contractual Clauses.
• OpenRouter (OpenRouter, Inc.) and selected hosted model providers — Optional routing of AI-assisted review-reply draft requests through OpenRouter to selected hosted model providers when the AI feature is enabled. OpenRouter and the selected inference provider receive only the review text and prompt context needed to generate the draft; production routing is limited to approved providers and configured to deny provider data collection or require zero data retention where supported.
  Location: United States; selected inference-provider location depends on the routing configuration · Transfer safeguard: OpenRouter Data Processing Agreement and EU Standard Contractual Clauses; provider-specific safeguards confirmed before production use.
• Vercel (Vercel, Inc.) — Application hosting and content delivery.
  Location: United States (an EU region is available) · Transfer safeguard: EU Standard Contractual Clauses; EU–US Data Privacy Framework.

7. Data retention

Contact personal data is retained only while needed for review-request workflows. By default, contact email, first name, phone number and normalized email are purged 365 days after the contact's last interaction. The contact's non-identifying metadata, audit logs, message records with personal data removed, and suppression records are retained so that compliance history and opt-outs survive deletion.

Account data is retained while your account is active and is deleted within a reasonable period (generally up to 90 days) after the account is closed, unless longer retention is required by law. First-party analytics events are retained for up to 24 months. Audit logs are retained for as long as needed for security and to meet statutory obligations. Billing, accounting and tax records are retained for the periods required by Slovak law (generally up to 10 years).

8. International transfers

Our primary application database is hosted in the European Union (Frankfurt). Some sub-processors still process personal data outside the European Economic Area, such as email delivery and application hosting in the United States. Where personal data is transferred outside the EEA, we rely on an adequacy decision, the EU–US Data Privacy Framework, and/or the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914) together with any supplementary measures that are needed. Before relying on Standard Contractual Clauses we assess the recipient country's law and apply supplementary measures such as encryption in transit and at rest, and those clauses give affected individuals enforceable rights and effective remedies. You may request a copy of the safeguards in place at [email protected].

9. Your rights

Subject to applicable law, you have the right to access, rectification, erasure, restriction, data portability and objection, and the right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal. To exercise these rights, contact [email protected]; account holders can also export contact data in the product as a JSON and CSV bundle.

Where a request concerns contact data that a customer uploaded, the customer is the controller and the request should normally be directed to that customer; we assist customers in fulfilling valid requests.

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing.

You have the right to lodge a complaint with a supervisory authority, in particular the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov SR), Galvaniho 7/B, 821 04 Bratislava, dataprotection.gov.sk.

10. Cookies and analytics

Townproof's authoritative analytics ledger is its own first-party analytics_events table. Strictly necessary cookies (such as the sign-in cookie) are always set. Non-essential first-party analytics cookies (nk_anon, nk_utm, nk_session), browser analytics and session replay require prior consent and remain off unless you grant it. PostHog browser analytics and session replay are disabled by default; error monitoring (Sentry) is configured to scrub personal data; Google Maps may set cookies on pages or widgets that display a map. Personalized audit or report links contain a pseudonymous recipient identifier. When one of these URLs is requested, we record server-side that the report was served and use that record to attribute campaign response. This server-side handling does not itself store or read information on your device. We process this pseudonymized data for a limited period on the basis of our legitimate interests in campaign attribution and service measurement; you may object at any time under Section 9. IP addresses and the visitor identifier used on tracked review links are likewise treated as pseudonymized personal data and processed for a limited period on the basis of our legitimate interests in click attribution and anti-abuse. We do not use third-party advertising pixels. See our Cookie Policy for details.

11. How we protect personal data

We apply appropriate technical and organizational measures, including encryption in transit, access controls and least-privilege access, tenant isolation between customers, pseudonymization and tombstoning of purged data, logging, and backup and breach-response procedures. No method of transmission or storage is completely secure, but we work to protect personal data in line with Article 32 GDPR.

12. Changes of controller and business transfers

The data controller is currently advixory s.r.o. We may transfer our business, or part of it, including this service and the personal data we process in connection with it, to a successor or affiliated entity, for example as part of a merger, reorganization, or sale of the business or its assets. If the identity of the controller changes as a result, we will update this Policy to identify the new controller and notify you before or at the time the change takes effect, in accordance with Articles 13 and 14 GDPR. The new controller will continue to process your personal data for the same purposes and under the same safeguards unless we tell you otherwise. Where we and the new entity are part of the same group, we may transmit personal data within the group for internal administrative purposes on the basis of our legitimate interests (Recital 48 GDPR).

13. Changes to this Policy

We may update this Policy when the service, the law or our operations change. Material changes will be communicated through the product, by email, or on the website, and the "Last updated" date will be revised.

14. Contact and data protection officer

We are not legally required to appoint, and have not appointed, a Data Protection Officer. Privacy, Data Processing Agreement and data-subject requests can be sent to [email protected] or to advixory s.r.o. at the registered seat above.

15. United States privacy rights

Townproof is a business product offered primarily in the European Union, and we do not sell or share your personal information and do not use it for cross-context behavioral advertising. If you are a resident of California or another US state with a comprehensive privacy law, you may, subject to that law, have the right to know or access the personal information we hold, to delete or correct it, to opt out of any sale or sharing (we do none), to limit the use of sensitive personal information (we do not use it beyond providing the service), and not to be discriminated against for exercising these rights. To exercise a right, or to appeal a decision, contact [email protected]; you may use an authorized agent, and we may verify your identity before acting. Most of the data we process is business-context data or is processed on behalf of our customers, which is generally outside these state laws; where we act on a customer's behalf, we will refer your request to that customer and assist them.