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").

We are the controller for account, billing, website, security and product-usage data, for public reports and for business prospecting (Section 4). For contact data and other data that business customers submit 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, role, authentication events (including magic-link sign-in) and settings.
• Contact data submitted by customers: contact email, normalized email, first name and phone number, from uploads, manual entry or the customer's connected booking or intake system. This data originates from our customers, who collected it from their own contacts and customers.
• Review and reply data: review text, ratings and any names in them that you paste for an AI reply draft, the generated draft, and replies that recipients send to review-request emails.
• Business and report data: business names, addresses, Google Business Profile links, ratings and review counts, websites and categories of your business and of nearby rivals; the questions we ask AI assistants, their answers, the businesses and sources they name, and the findings and fixes we derive.
• Free report and report-update data: the business you look up, the location, the rivals you pick, your email address if you ask for the report or updates, and a hashed IP address used for rate limiting.
• Business prospect data: for businesses we contact about Townproof, the business name, public contact details (such as a public business email address or the name of the owner or manager where published), the source of those details and our outreach history.
• Sales and feedback data: what you send us through contact or sales forms (contact details, business details, number of locations, notes) and optional answers to our price survey.
• Usage and analytics data: product actions, page views, onboarding progress and feature events, linked to an account or organization identifier or an anonymous identifier.
• Technical data: IP address and information about the device and browser; for tracked review links, a daily-changing visitor fingerprint; personalized report links contain a pseudonymous identifier used to record that a report was served and attribute campaign response.
• Audit and compliance logs: sends, suppressions, consent and legal acceptances, token actions, billing changes, deletions, support sessions, the acting user, IP address where needed for compliance, and timestamps.
• Billing data: handled by our Merchant of Record (Polar); we receive limited subscription and invoice metadata.

3. Where the data comes from

Most data comes from you. Contact data comes from our customers. Business, rating and review-count data comes from public Google Maps and Places listings. AI answers come from the AI assistants we query. Business prospect contact details come from public business websites and, where used, from a business-data enrichment provider; we record the source for each prospect. We collect these details only about businesses, but a business contact can be a named person, and a sole trader's business name can identify a person.

4. How we use it and our legal bases (Article 6 GDPR)

Where we rely on legitimate interests, we have weighed them against your rights and freedoms. For contact data and other data customers submit, the customer is the controller and decides the purposes and legal basis; we act only on the customer's documented instructions under our Data Processing Agreement.

• Running your account and the service (sign-in, reports, AI visibility checks, review requests, support): to perform our contract with you (Article 6(1)(b)). If you act for a business customer, we process your contact and account data on the basis of our legitimate interest in running the business relationship with that customer (Article 6(1)(f)).
• Billing: through Polar as Merchant of Record, to perform the contract and to meet tax and accounting obligations (Article 6(1)(b) and (c)).
• Public reports and comparisons: to show businesses how they compare with nearby rivals, based on our legitimate interest in providing public comparisons of public business information (Article 6(1)(f)).
• AI visibility checks: we send local questions (with business names and locations, never contact data) to AI assistants and keep their answers to produce, compare and explain reports (Article 6(1)(b) for your checks, Article 6(1)(f) for free-report samples).
• Report updates you ask for: if you enter your email on a free report, we email the report and then re-check the Google review gap and email you about 4 days later and then up to three times at monthly intervals. Every update email has an unsubscribe link, and you can also stop updates at any time by writing to [email protected]. Basis: our legitimate interest in following up a request you made (Article 6(1)(f)).
• Business prospecting: we email businesses that may benefit from Townproof, with a link to their report. Basis: our legitimate interest in promoting our service to businesses (Article 6(1)(f)). You can object at any time, and we will stop.
• Sales enquiries and price research: to answer your enquiry and to assess pricing (Article 6(1)(b) at your request, or Article 6(1)(f)). Survey answers do not change your price.
• Product analytics: we record service events (such as sign-up, AI checks and payments) linked to your account in our own database and in PostHog, to measure how the service is used and whether it works (Article 6(1)(f)). This works without cookies and is separate from browser analytics; if you accepted analytics cookies, the sign-up event also includes the browser analytics identifiers and campaign tags from those cookies. You can object by writing to [email protected], and we will stop sending your account's events to PostHog.
• Browser analytics and session replay: only with your consent in the cookie banner (Article 6(1)(a) GDPR and §109(8) of Act No. 452/2021 Coll.). You can withdraw consent at any time through Cookie settings.
• Security, abuse prevention and support sessions: to protect the service and our customers (Article 6(1)(f)). Authorized staff may access an account through a time-limited, logged support session to fix problems or investigate security issues; we record who did it.
• Legal and compliance records, including consent and legal acceptances, suppressions and data-subject requests (Article 6(1)(c) and (f)).
• Optional AI reply drafts: only when you ask for one (Article 6(1)(b)).

5. What you must provide

You need an email address to create and sign in to an account; without it we cannot provide access. Some features need business details (for example your Google Business Profile) to work. Everything else, including report-update emails, the price survey and analytics consent, is optional, and refusing analytics does not limit your use of the service.

6. Direct marketing and your right to object

You can object at any time, without giving a reason, to the use of your personal data for direct marketing, including report updates and prospecting emails. Use the unsubscribe link or reply in the email, or write to [email protected], and we will stop. We keep a short suppression record so we do not contact you again. For email marketing we also follow §116 of Act No. 452/2021 Coll. and the email laws of the recipient's country, such as the US CAN-SPAM Act.

7. 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.

8. Recipients and sub-processors

We use the service providers listed below. The Data Processing Agreement uses the same list; entries marked as independent controllers are not sub-processors. 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. If we start using an email-sending platform for business prospecting, we will add it to this list before we use it.

• 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.) — independent controller — 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.) — Product analytics. Browser analytics and masked, sampled session replay run only after you accept analytics in the cookie banner. Separately, our servers send service events (such as sign-up, AI checks and payments) linked to an account or organization identifier, based on our legitimate interests (Privacy Policy Section 4); they do not need cookies, but if you accepted analytics cookies, sign-up events also include the browser analytics identifiers and campaign tags stored in them. Townproof's own database remains the authoritative analytics ledger. Browser traffic reaches PostHog through our subdomain t.townproof.com, which PostHog routes through its sub-processor Cloudflare.
  Location: European Union (Frankfurt, Amazon Web Services); PostHog, Inc. is a United States company and its staff may access data remotely; Cloudflare routing may use edge locations outside the EU · Transfer safeguard: Event data stored in the EU. Remote access by PostHog, Inc. staff relies on the EU–US Data Privacy Framework, under which PostHog, Inc. states it is certified. PostHog's data processing agreement is not yet signed. Client IP addresses are not stored.
• Google (Google Ireland Limited) — Google Maps and Places lookups for business-profile data, competitor and audit information; Gemini API (paid tier) for AI visibility checks, which receives business names, locations and search questions, not contact data. On the paid tier Google does not use prompts or answers to improve its products.
  Location: European contracting entity (Google Cloud EMEA Limited for the Gemini API); processing may occur globally · Transfer safeguard: EU–US Data Privacy Framework; EU Standard Contractual Clauses.
• Cloudflare (Cloudflare, Inc.) — Authoritative DNS for Townproof's domains, and R2 object storage for generated AI visibility reports (deleted after 365 days).
  Location: United States company; global network. The R2 bucket is set to prefer Eastern Europe, which Cloudflare treats as best effort, not a guarantee of EU-only storage or processing · 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 (OpenRouter; inference currently limited to DeepInfra, Inc. and Fireworks AI, Inc., both United States) · Transfer safeguard: OpenRouter Data Processing Agreement and EU Standard Contractual Clauses; provider data collection denied in routing. We will update this entry before routing to other providers.
• Railway (Railway Corporation) — Hosting of the API and background workers (review-request sending, review polling, AI visibility checks). Processes account, contact and message data in memory; the database stays with Neon in the EU.
  Location: United States (Virginia) · Transfer safeguard: Railway's terms of service. Railway's data processing agreement, which includes the EU Standard Contractual Clauses, is not yet signed. Our database stays in the EU.
• Vercel (Vercel, Inc.) — Hosting of the website and web application, and content delivery.
  Location: Server functions in the European Union (Frankfurt); global edge network for content delivery; United States company · Transfer safeguard: EU Standard Contractual Clauses; EU–US Data Privacy Framework.

9. Data retention

• Contact identifiers (email, normalized email, first name, phone number): purged 365 days after the contact's last interaction, or after creation if there was none, unless a send is in progress. Non-identifying metadata, audit logs, message records with personal data removed and suppression records are kept so that compliance history and opt-outs survive deletion.
• AI reply drafts and the review text they contain: 90 days.
• Free reports, report-update subscriptions and business prospect records that did not lead to an account: personal data removed 12 months after the last activity. A minimal suppression record is kept if you unsubscribed or objected. Reports that led to an account are kept with that account. If you asked us to set up an account, that request (your email, business name and Google listing) is kept in our sales records as evidence of what you asked for, also when set-up did not complete.
• Raw answer text from AI visibility checks: 90 days. Short quoted excerpts in free-report samples: 90 days from the original sample. Counts, cited sources and findings derived from the answers are kept with the report. Generated report files: 365 days.
• Tracked review link records: 13 months.
• Product analytics events in our database: 24 months. PostHog keeps events for 1 year and session replays for up to 30 days.
• Account data: while your account is active and deleted within a reasonable period (generally up to 90 days) after the account is closed, unless the law requires longer.
• Sales enquiries and price-survey answers: as long as needed for the enquiry or pricing work, and no longer than 24 months.
• Audit logs: as long as needed for security and to meet legal obligations. Billing, accounting and tax records: for the periods required by Slovak law (generally up to 10 years).

10. International transfers

Our primary database is hosted in the European Union (Frankfurt). Some service providers process personal data outside the European Economic Area, mainly in the United States: application hosting, email delivery, AI assistants, content delivery and routing, and remote access by providers' staff. Where personal data is transferred outside the EEA, we rely on an adequacy decision (including the EU–US Data Privacy Framework where the specific recipient is certified) or on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914) in the provider's data processing terms, together with any supplementary measures that are needed. We assess the recipient country's law before relying on Standard Contractual Clauses. You may request a copy of the safeguards at [email protected]. The provider list in Section 8 shows the safeguard for each provider, including where a data processing agreement is not yet signed.

11. 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 submitted, 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. AI visibility results describe how AI assistants answered; they are not decisions about you.

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.

12. 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 masked session replay load only after you accept analytics in the cookie banner; if you reject or do not choose, PostHog does not run and no data is sent to it from your browser. Server-generated service events are described in Section 4. Error monitoring (Sentry) is configured to scrub personal data; Google Maps may set cookies on pages or widgets that display a map. Personalized 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. IP addresses and the visitor fingerprint used on tracked review links are treated as pseudonymized personal data and used for click attribution and abuse prevention on the basis of our legitimate interests; you may object at any time under Section 11. We do not use third-party advertising pixels. See our Cookie Policy for details.

13. 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, logged and time-limited support access, 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.

14. 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).

15. 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.

16. 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.

17. United States privacy rights

Townproof is operated from Slovakia and serves business customers internationally, including local businesses in the United States. We do not sell or share 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. Whether a state law applies depends on its thresholds and exemptions; business contact information is not exempt in every state, and California law can cover it. Where we act on a customer's behalf, we will refer your request to that customer and assist them.