Privacy Policy

1. Data We Collect

We collect the following categories of personal data:

1.1 Personal Information

• Identification details: name, property address, and apartment number
• Contact details: phone number and email address, used to reach you and to send service-related notifications
• Company and organization information
• Your role within organizations (e.g., resident, shareholder, prospective resident, property manager, employee)

1.2 Web-Chat Widget Data

• Messages you type into the Renocount chat widget on a customer's website
• Any contact details you voluntarily provide in chat (e.g., name, email, phone number, address)
• Files or images you upload to the chat as attachments
• Conversation transcripts, AI tool/function-call traces, and session/visitor identifiers used to maintain conversation context
• Page/site context where the widget is loaded (e.g., referring URL, the customer organization the widget belongs to)

1.3 Phone Assistant Data (AI Phone Calls)

• Caller phone number (CLI), called number, call start/end time, duration, and routing decisions (e.g., business-hours forwarding to a human vs. AI handling)
• Call audio, processed only momentarily for real-time speech-to-text conversion. We do not record calls: no raw audio recordings (e.g., MP3/WAV) are stored in our systems or those of our sub-processors
• The text transcript of the conversation produced by the phone assistant, and the AI tool/function calls executed during the call
• Call summaries and tickets produced from the call, delivered to the customer organization (e.g., by email, text message, or into its property management system)

Because call audio is not stored and is not used to uniquely identify a person, we do not process biometric data within the meaning of Article 9 GDPR.

1.4 Knowledge Base and Source Data

• FAQ entries, policies, documents, and other reference material that the customer organization enters or uploads, or that we ingest from publicly accessible URLs it provides (e.g., via a web crawler), to ground the AI's responses
• Building- and property-level facts extracted from conversations. Personal data is automatically filtered out, and only anonymized facts are stored after a property manager has reviewed and approved them
• Embeddings and indexed representations of that material used for retrieval

1.5 Billing and Payment Status (Real-Time Lookup)

• For questions about invoices or rent status, the assistant may look up the relevant information from the customer's connected financial management software through a secure API, solely to answer the question in real time
• We do not store, cache, or save residents' financial history or bank account details in our own databases

1.6 Technical Data

• IP address, browser type, device information, and language
• Website and widget usage and navigation patterns
• System logs, error reports, and audit logs of AI tool calls

2. Why We Process Your Data

We process personal data for the following purposes:

2.1 Web-Chat Widget

• Operating the embedded chat widget and answering visitor questions in real time
• Generating grounded responses from the customer's FAQ/knowledge base via OpenAI models
• Maintaining conversation state and history within a session, and across sessions where a visitor identifier is available
• Forwarding qualified leads, contact requests, or escalations to the customer organization (e.g., as an email notification via Resend)

2.2 Phone Assistant (AI Phone Calls)

• Receiving inbound calls through Twilio and, depending on business-hours and routing rules, either forwarding the call to a human or handling it with the AI assistant
• Converting the caller's speech to text in real time with OpenAI in order to understand the caller and respond
• Producing a text transcript and summary of the call and triggering follow-up actions (e.g., creating a ticket, texting a link to a form, escalating to a human)
• Operating safety, abuse, and quality controls on the call flow

2.3 CRM and Service Notifications

• Storing chat transcripts and call transcripts in the customer organization's CRM so that its staff can follow up on requests
• Sending transactional, service-related email notifications (e.g., a new ticket, a lead, or a call summary) to the customer organization or the resident via Resend

2.4 AI Processing (Shared Across Channels)

• Sending the minimum necessary content (messages, transcripts, knowledge snippets) to OpenAI as our AI sub-processor in order to generate responses, transcripts, summaries, and tool calls
• Maintaining short-lived conversation context, tool/function-call traces, and audit logs
• Operating safety filters and rate limits

2.5 Service Improvement

• Analyzing aggregated usage patterns to improve platform functionality
• Enhancing AI conversation and routing capabilities
• Optimizing user experience and interface design

Personal data, including chat logs and call transcripts, is never used to train, retrain, or fine-tune public or foundation AI models.

2.6 Legal and Business Operations

• Comply with legal obligations and regulations
• Establish and maintain business relationships
• Respond to inquiries and service requests
• Ensure platform security and prevent fraud

3. Legal Basis for Processing

We process your personal data based on:

• Contract performance: To fulfill our obligations when providing services, including processing service requests and delivering agreed functionality
• Legitimate interests: To respond to inquiries, operate and secure our services, support ongoing projects, and coordinate service routing data (balanced against your rights)
• Consent: When you voluntarily provide information through forms or communications (you may withdraw consent at any time)
• Legal obligation: To comply with applicable laws and regulations

4. Data from Third Parties

Telephony provider (Twilio): When a caller dials a phone number connected to Renocount, Twilio passes call signalling data (caller number, called number, timestamps) and the call's real-time audio to us. The audio is processed only for real-time speech-to-text conversion and is not recorded.

Financial management software: Where a customer organization has connected its financial management software, we retrieve invoice or rent-status information through a secure API only to answer a specific question in real time. This information is not stored in our databases.

Customer websites embedding the chat widget: When a visitor interacts with the chat widget on a Renocount customer's website, we receive the messages, attachments, and session metadata sent by that visitor as described in §1.2.

5. Sub-Processors and Third-Party Services

To deliver the web-chat widget, the AI phone assistant, and related service notifications, we rely on the following sub-processors. Each is bound in writing to data protection obligations at least equivalent to our own Data Processing Agreement (DPA) and, for transfers outside the EU/EEA, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.

A current and authoritative list of sub-processors is maintained as the "Sub-processor List" attached to our Terms of Service and is available on request. We notify customer organizations in writing at least 30 days before adding or replacing a sub-processor.

6. Data Storage and Retention

Our primary database and storage infrastructure (Supabase / AWS) is located in Stockholm, Sweden (EU/EEA). Each customer organization's data and knowledge base is technically isolated and is never shared with, or used to generate answers for, other customers.

6.1 Data Retention Periods

• Call audio (phone assistant): never stored. Audio is processed only momentarily for real-time speech-to-text conversion
• Chat transcripts and call transcripts: stored in the customer organization's CRM and retained for 12 months after the matter is resolved, then irreversibly deleted or anonymized. The customer organization can delete them earlier at any time or set a shorter retention period
• Billing and rent-status information: not stored; retrieved in real time only to answer the question
• Knowledge base: retained for the duration of the customer's service agreement; returned or deleted when the agreement ends (see below)
• Attachments & media uploaded in chat: retained for up to 24 months unless legal retention applies
• User accounts: retained until account deletion or 3 years of inactivity
• Technical and audit logs (including AI tool-call traces): retained for up to 12 months for security and debugging purposes

When a customer's service agreement ends, we delete or return (at the customer's choice) all personal data and the knowledge base in a machine-readable format within 30 days, unless EU or Finnish law requires longer retention. Any copies in backups are deleted in the normal backup cycle within 90 days.

We may retain data longer only where required by law. You can request data deletion at any time, subject to legal obligations.

7. Data Sharing

We do not sell your personal data. We may share it:

• With the sub-processors listed in §5, who help us operate the web-chat and phone assistant (under data protection agreements)
• With the customer organization (e.g., your housing management company) that operates the chat widget or phone number you are interacting with. It is the data controller for that interaction
• When required by law or to protect our legal rights
• With your explicit consent

8. Your Rights Under GDPR

Under the EU General Data Protection Regulation (GDPR) and Finnish Data Protection Act (Tietosuojalaki), you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we process your data
• Portability: Receive your data in a structured format
• Object: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent
• Lodge a complaint: With the Finnish Data Protection Authority (Tietosuojavaltuutetun toimisto)

8.1 How to Make a Data Request

Residents and other people contacting a housing management company through Renocount: your housing management company is the data controller. Please send your request to it directly. If you contact us instead, we will forward your request to the controller without delay rather than answering it ourselves. Our platform lets the controller immediately identify, export, or delete all data concerning an individual resident, for example when a resident moves out.

Where Renocount is the controller (e.g., website visitors and customer contacts): contact us at christian.ahlstrom@renocount.com. We will confirm receipt and respond within 30 days. We may request additional information to verify your identity.

9. Cookies, Local Storage and Analytics

The Renocount web-chat widget uses first-party local/session storage on the customer site (and, where applicable, a first-party cookie) to keep your conversation continuous across page navigations. We do not use cross-site tracking cookies and we do not run third-party advertising trackers inside the widget.

Our website may use cookies and similar technologies to:

• Ensure proper website functionality
• Analyze website usage (we aim to use aggregated or anonymized data where possible)
• Improve user experience

You can control cookie settings through your browser preferences. Where required, we obtain your consent via a cookie banner.

10. Updates to This Policy

We may update this privacy policy from time to time. Changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

11. Automated Decision-Making and AI

The web-chat widget and the phone assistant use large language models to generate responses. The system only provides customer-service guidance and forwards inquiries:

• The phone assistant can escalate or transfer the call to a human, and (during business hours, where configured) inbound calls are routed to a human first
• Web-chat answers are returned in real time; visitors can always request a human follow-up
• Updates to the knowledge base require manual review and approval by the property manager before they are saved
• Personal data, including chat logs and call transcripts, is never used to train, retrain, or fine-tune public or foundation AI models

We do not make decisions producing legal or similarly significant effects on you that are based solely on automated processing, including profiling, within the meaning of Article 22 GDPR.

12. Data Protection and Security

We implement technical and organizational measures in accordance with Article 32 GDPR, including:

• Encryption at rest (AES-256) and in transit (TLS 1.2 or newer)
• Role-based access control and the least-privilege principle; only named, trained personnel can access production data, and access requires multi-factor authentication
• Logging of access and processing activities, with regular log monitoring
• Backups, recoverability, and regular testing and evaluation of these measures

All personnel authorized to process personal data are bound by a legally binding duty of confidentiality. In the event of a personal data breach, we notify the affected customer organization without undue delay and no later than 24 hours after becoming aware of it.

13. International Data Transfers

Our primary storage (Supabase / AWS, Stockholm) and hosting (Fly.io) are in the EU. Some sub-processors used for the web-chat, phone assistant, and service notifications (in particular OpenAI, Twilio, and Resend) may process data outside the EU/EEA. Where such transfers occur, they are based on the European Commission's Standard Contractual Clauses (SCC) or another transfer mechanism under Chapter V GDPR, together with the technical and organizational measures described in §12.

14. Processing Roles and Responsibilities

Depending on the service context, we act either as:

• Data processor for resident and customer-service data handled through the web-chat, phone assistant, knowledge base, and CRM. Here the customer organization (the housing management company) is the controller
• Data controller when we collect personal data directly for our own purposes (e.g., website visitors and customer contacts)

When acting as a processor, we process data only under the controller's documented instructions and in accordance with our Data Processing Agreement (DPA), which meets the requirements of Article 28(3) GDPR. The knowledge base and its content belong exclusively to the customer organization; we do not use it for our own purposes or for the benefit of other customers.

15. Children’s Data

Our services are not directed to children. We do not knowingly collect personal data of individuals under 16. If you believe a child has provided personal data, please contact us so we can delete it.