Privacy Policy
1. Who we are
Avercentris ("we", "us", "our") provides an AI-assisted customer operations platform for businesses. This policy explains how we collect, use, and protect personal data when you visit our website, use our platform, or interact with an AI assistant powered by Avercentris on one of our customers' websites.
Data controller: Avercentris, [LEGAL ENTITY NAME], [REGISTERED ADDRESS], Ireland. Contact: info@avercentris.com.
2. Two roles: when we're the controller, and when we're the processor
This distinction matters and applies differently depending on how you're interacting with us:
- We are the data controller for visitors to avercentris.com and for our own paying customers' account data (billing contacts, login details, usage data).
- We are the data processor when our AI assistant is embedded on a customer's website (for example, a Nomo Mobile or similar business using our platform). In that case, the business you're talking to is the data controller, and we process the conversation data on their behalf, under a Data Processing Agreement with them.
If you're a visitor chatting with an AI assistant on one of our customers' websites, that business's own privacy policy governs how your data is used — this page describes how Avercentris, as their processor, handles it on their behalf.
3. What data we collect
| Category | Examples |
|---|---|
| Contact data | Name, email address, phone number |
| Conversation data | Messages sent to the AI assistant or a human agent, timestamps |
| Technical data | IP address, browser type, device information |
| Account data (our own customers) | Billing details, login credentials, usage and configuration data |
4. Why we process this data (legal basis)
- Contract — to provide the service you or a business you're contacting has requested (Art. 6(1)(b) GDPR)
- Legitimate interest — to improve AI accuracy, detect and prevent misuse, and maintain security (Art. 6(1)(f))
- Consent — for optional cookies/analytics, where applicable (Art. 6(1)(a))
- Legal obligation — where we're required to retain certain billing or compliance records
5. AI processing — what you should know
When you interact with an Avercentris-powered assistant, your message is processed by an AI language model to generate a response. We use third-party AI infrastructure providers (see Section 6) to do this. Conversations are grounded in a knowledge base configured by the business you're speaking with — the AI does not have general internet access and is instructed not to invent information outside that knowledge base.
You are always entitled to know you're speaking with an AI system, and to request a human at any point in the conversation.
If you send a file through the chat, it's automatically checked for security threats — such as embedded malicious code — before it's added to the conversation. Files that don't pass this check are rejected rather than stored or shared.
6. Who else sees this data (sub-processors)
We use the following categories of sub-processor to operate the platform. An up-to-date, named list is available on request at info@avercentris.com.
| Purpose | Provider (example) | Location |
|---|---|---|
| AI language model inference | [OpenRouter / underlying model providers] | USA — DPF-certified or SCCs in place |
| Text embeddings for knowledge retrieval | [OpenAI] | USA — DPF-certified or SCCs in place |
| Email delivery | [Mailgun] | [EU/USA — confirm] |
| Hosting & infrastructure | [Hostinger] | [Confirm data centre region] |
| Internal team notifications | [Telegram] | [Confirm — Telegram's data handling should be reviewed separately] |
Where a sub-processor is located outside the EEA, we rely on the EU–US Data Privacy Framework where the provider is certified, or Standard Contractual Clauses where it is not. [This section must be verified against each provider's current certification status before publishing — these change over time.]
7. How long we keep data
[PLACEHOLDER — define retention periods, e.g.: Conversation data is retained for 12 months after the last interaction, then automatically deleted, unless a longer period is required by the business we're processing data for, or by law. Account data for our own customers is retained for the duration of the contract plus [X] years for accounting/legal purposes.]
8. Your rights
Under GDPR, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Request deletion ("right to be forgotten")
- Restrict or object to certain processing
- Request a copy of your data in a portable format
- Lodge a complaint with the Irish Data Protection Commission (dataprotection.ie) or your local supervisory authority
To exercise any of these rights, contact info@avercentris.com. If your request concerns a conversation with a specific business using our platform, we may need to direct you to that business first, since they are the data controller for that conversation.
9. Security
[PLACEHOLDER — briefly describe technical/organisational measures once finalised: encryption in transit, access controls, API key rotation policy, etc.]
10. Changes to this policy
We may update this policy from time to time. Material changes will be noted on this page with an updated "last updated" date.
11. Contact
Questions about this policy or how your data is handled: info@avercentris.com