Legal

Privacy Policy

What avatarx collects, why, where it is stored, and the rights you have over it. Written to be specific about this system rather than generic — including the fact that everything described here is stored in our database.

Last updated 23 September 2026

Who we are

avatarx is a platform for building AI avatar agents that talk with visitors on your website. This policy covers the avatarx website, the dashboard at avatarx.net, the API, and the embeddable chat widget.

The data controller for account data is [Company legal name], [registered address], reachable at [privacy@avatarx.net]. If we have appointed a data protection officer or an EU representative, their contact details are [contact].

Controller or processor — which applies to you

Two different relationships exist, and your rights differ between them:

If you are…We act asWhat that means
an account holderControllerWe decide how your account, agents and billing data are handled. Contact us directly to exercise your rights.
a visitor who spoke to an agentProcessorThe business that embedded the agent decides what is collected and why. We only process it on their instructions. Contact that business first; we will help them respond.

What we collect and store

Everything below is stored in our database

Account details, agent configuration, uploaded knowledge and media, and full conversation transcripts are written to a PostgreSQL database on our servers, with uploaded files on the same server's disk. They are not ephemeral: they persist until you or the account holder deletes them, or the account is closed.

Account and security data

DataNotes
Email address, name, passwordThe password is stored only as a bcrypt hash — never in readable form.
Sign-in historyLast sign-in time and IP address, failed attempt counts and lockout state.
SessionsOne row per signed-in device: a hash of the session token, IP address, browser user-agent, creation, last-seen and expiry times.
Google connectionIf you connect Google Calendar: your Google email and a refresh token, stored encrypted.
Email (SMTP) settingsHost, port, username and sender addresses; the password is stored encrypted and never returned by the API.
Credit balanceMinutes granted and consumed.
Audit logSecurity-relevant administrative actions, with actor and IP address.

What you build

DataNotes
Agent configurationName, prompt, personality, voice, avatar, language, model choice, greeting, conversation starters, topics to avoid and capability switches.
Knowledge base contentThe full text of every document you upload, paste or crawl, plus the numeric embeddings generated from it and the original files on disk.
MediaImages, PDFs and videos you upload for agents to show, stored as files with their titles and keywords in the database.
Custom toolsWebhook URLs, headers and parameter schemas. Credentials are stored encrypted and are never returned by the API.

Conversations and the people in them

DataNotes
Conversation sessionsWhich agent, a visitor identifier, room name, start and end time, duration and status.
TranscriptsEvery message in the conversation — what the visitor said and what the agent replied — with timing information.
Visitor profilesName and email if the visitor gives them in the pre-chat form, plus whether they skipped it.
LeadsName, email, phone, company, interest and notes that an agent captured during a conversation, with a status and score.
AppointmentsVisitor name, email, phone, the booked time, timezone, purpose and notes.
Support ticketsMessages you send us for help, and our replies.

We do not collect special category data (health, biometrics, political opinions and similar) deliberately, and agents should not be configured to ask for it. Anything a visitor volunteers in a conversation is stored in the transcript as typed or spoken.

Why we process it, and on what legal basis

PurposeLegal basis (UK/EU GDPR)
Creating your account and running the service you asked forPerformance of a contract (Art. 6(1)(b))
Storing agents, knowledge, media and transcripts so the product worksPerformance of a contract
Securing accounts: sign-in throttling, session management, audit loggingLegitimate interests (Art. 6(1)(f)) — keeping accounts safe
Answering support requestsPerformance of a contract / legitimate interests
Sending service emails such as booking confirmationsPerformance of a contract
Meeting legal and accounting obligationsLegal obligation (Art. 6(1)(c))
Processing visitor data inside your agents' conversationsOn the account holder's instructions, as processor (Art. 28)

We do not sell personal data, and we do not use it for advertising or profiling.

Where it is stored

  • Application data lives in a PostgreSQL database on a dedicated virtual server rented from Contabo, located in [data-centre region — confirm before publishing].
  • Uploaded documents, media and avatar files are stored on that same server's disk.
  • Redison the same server holds short-lived job and queue state. Both the database and Redis listen only on the server's loopback interface — they are not reachable from the internet.
  • Some processing necessarily leaves that server: see the sub-processors below.

Who else processes it

To answer a visitor in real time, parts of a conversation are sent to specialist providers. We use only what the product needs:

ProviderWhat it receivesPurpose
OpenAIThe composed prompt, recent conversation turns and any retrieved knowledge excerptsGenerating replies
AnthropicThe same, when you select a Claude modelGenerating replies
CartesiaThe text the agent is about to saySpeech synthesis
LiveKitReal-time audio and video streams and room metadataCarrying the live call
HeyGen / LiveAvatarThe agent's speech and avatar identifierRendering the talking avatar
RunPodShort audio segments and the avatar identifierGPU lip-sync rendering
GoogleYour Google account identity, and booking details if you connect CalendarSign-in, Calendar events and Meet links
Your own SMTP serverBooking confirmations and handoff alertsSending email from your domain

Speech recognition runs on our own server rather than a third-party service. Where a provider is outside the UK/EEA, transfers rely on the European Commission's Standard Contractual Clauses or an adequacy decision — see [link to your transfer documentation].

Your own webhooks

If you configure a custom tool, the agent will send the arguments you defined to the URL you chose. That endpoint is yours, and what it does with the data is your responsibility.

AI processing

  • Replies are generated by the model provider you select per agent. Prompts, retrieved knowledge and recent conversation turns are sent to them for that purpose.
  • Under those providers' API terms, content sent through the API is not used to train their models by default. Confirm the current terms of the provider you choose.
  • Agents can be configured with memory, which lets them recall a returning visitor's earlier conversations with the same agent — or, if the account holder enables sharing, with their other agents.
  • Automated replies are not used to make decisions with legal or similarly significant effects.

How long we keep it

DataKept
Agents, knowledge, mediaUntil you delete them. Deleting an agent also deletes its knowledge base, documents, embeddings, media and conversations.
Conversations and transcriptsUntil deleted with the agent or the account. Conversations that end without a single message are discarded automatically.
Leads and appointmentsUntil you delete them or the agent they belong to.
Account dataFor the life of the account. Closing the account removes your agents and their data.
SessionsExpire after 7 days, or 3 days without use; you can revoke them sooner.
Audit logs and security recordsRetained for security and accountability.
Backups[state your backup retention period]

Be accurate about this one

There is no automatic expiry of transcripts today — they persist until something is deleted. If you need a shorter retention period, delete the data or ask us and we will remove it.

Your rights under the GDPR

If you are in the UK or the EEA you have the following rights. They apply to personal data we hold about you as a controller; for data inside an account holder's agents, ask that business.

  • Access — a copy of the personal data we hold about you.
  • Rectification — correct anything inaccurate. Most fields are editable in the dashboard.
  • Erasure — ask us to delete your data. Deleting an agent or closing the account does most of this immediately.
  • Restriction — ask us to pause processing while a dispute is resolved.
  • Portability — receive your data in a machine-readable form. Leads export to CSV in the dashboard, and the API returns agents, knowledge and conversations as JSON.
  • Objection — object to processing based on legitimate interests.
  • Withdraw consent — where processing relies on consent, withdraw it at any time without affecting past processing.
  • Complain— to your local supervisory authority. In Germany that is the data protection authority of your state; in the UK, the Information Commissioner's Office.

Write to [privacy@avatarx.net] and we will respond within one month, as the GDPR requires. We may ask you to confirm your identity first.

How we protect it

These are the measures actually in place:

  • In transit — HTTPS everywhere, with HSTS and an automatic redirect from plain HTTP. Certificates renew automatically.
  • Passwords — hashed with bcrypt; we cannot read them.
  • Sessions — only a SHA-256 hash of each session token is stored, in an HttpOnly, Secure cookie, with a sliding expiry, an idle timeout and instant revocation.
  • Brute-force protection — accounts lock after five failed sign-ins, with a backoff that grows on repetition.
  • Secrets at rest — SMTP passwords, Google refresh tokens and custom-tool credentials are encrypted before they are stored, and are never returned by the API.
  • Tenant isolation— every request is scoped to the account that made it; another account's data returns “not found”.
  • Outbound guard — custom tool URLs must be public HTTPS; requests to internal or private network addresses are refused, so a tool cannot be used to reach our infrastructure.
  • Hardening — database and cache bound to loopback only, the application running as an unprivileged user, and security headers (X-Frame-Options, X-Content-Type-Options, Referrer-Policy, Permissions-Policy) on every response.
  • Audit logging — administrative actions are recorded with actor and IP address.

Being straight about the limits: transcripts and knowledge content are stored unencrypted at the field level, so a person with database access could read them. Access is limited to those who need it to operate the service. No system is perfectly secure; if a breach affects your data we will notify you and the relevant supervisory authority as the GDPR requires.

Cookies and local storage

  • One strictly necessary cookie — a session cookie set when you sign in. Without it you cannot stay signed in.
  • Browser storage— the dashboard keeps your session token and small preferences (such as the last agent you were configuring) in your browser's session and local storage. They never leave your device except as the session token on requests you make.
  • No advertising or analytics cookies, and no third-party tracking scripts on this site. Usage statistics in your dashboard are computed from your own conversations on our own servers.

If you talked to an avatarx agent on someone's website

The business running that agent decides what it asks for and why — they are the controller, and we process it for them. What is typically stored: the conversation transcript, any name, email or phone you provided, appointment details if you booked one, and technical session information.

To access or delete that data, contact the business whose site you were on. If you cannot reach them, write to [privacy@avatarx.net] and we will help identify the right controller and support their response.

Conversations are recorded as text

Speech is transcribed and the transcript is stored. Site owners are responsible for telling visitors this before a conversation begins, and for obtaining consent where their law requires it.

Children

avatarx is not intended for children under 16 and we do not knowingly collect their personal data. If you believe a child has provided data through an agent, tell us and we will delete it.

Changes and contact

We will update this policy when the product changes, and the date at the top will change with it. Material changes will be announced in the dashboard.

Questions, requests or complaints: [privacy@avatarx.net], or write to [Company legal name, registered address]. See also our Terms of Service.