· Privacy Policy · Activation Check

Privacy notice (operators)

Version gate-b-operator-notice-v2 · Guided setup sample only

Operator transparency notice for the internal activation check. This is not the full public privacy policy and is not independent counsel advice. Controller identity and transfer mechanisms remain as recorded in our legal schedule for guided setup.

Who this is for

Authenticated workspace operators who start or manage a guided sample activation check. It does not describe end-customer lead processing for live lead sources.

Purposes

  • Attribute guided activation starts for quota, abuse prevention, and support
  • Operate cancel, cleanup, and retention jobs for the sample lifecycle
  • Fulfil operator export and erase of activation linkage

Personal data categories

  • Operator user id and membership id (while retained)
  • Workspace and run status/timestamps
  • Pseudonymous replay/idempotency digests (cleared after operational window)
  • Synthetic sample lineage (sampleToken server-side; not returned on start DTO)

Not collected on the guided sample path:

  • Customer phone or email on the guided sample contact/lead
  • Live lead-source connection credentials in the sample path

Lawful basis

Legitimate interests (UK GDPR / GDPR Art. 6(1)(f) equivalent) for platform security, product integrity, and operator rights fulfilment — documented in the guided setup legitimate interests assessment. Owner may record Contract instead if the SaaS agreement covers this processing.

Retention

  • Start receipts: 24 hours logical expiry, hard-delete with ≤15 minute lag target
  • Operator linkage and digests: minimize after operational support window (≤30 days)
  • Minimized tombstone: hard-delete by retention expiry (≤90 days) unless legal hold

Who we share with

Hosting, database, and identity infrastructure processors used to run Dwellori (for example Neon PostgreSQL, Appwrite hosting/identity). Guided sample does not send sample contact data to messaging providers (Brevo/Telnyx) or LLM providers.

Your rights

You may request export or erase of operator activation linkage via workspace privacy APIs (operator-export / operator-erase). To object to legitimate-interests processing, contact the controller or use operator erase / request the feature be disabled for your workspace. End-customer lead rights go through the broker’s DSR path, not this notice.

Controller contact

Privacy requests: privacy@dwellori.com