Privacy policy

1. Two different situations

This policy covers two things that shouldn't be confused:

• Data of visitors to this website: people who visit the MOON Chat pages and fill out the contact form. Here we are the controller.
• Data of visitors to our clients' websites: people who talk to the chatbot installed on a client's store. Here we are a processor: the client decides why and how the data is processed, and we carry it out.

2. Data of visitors to this website

What we collect

• The data entered in the demo request form: name, website address, phone, email, the platform used and the optional message.
• The minimum technical data needed for operation and security: the IP address and the time of the request.

Why, and on what legal basis

• To answer your request and prepare your demo. The legal basis is taking pre-contractual steps at your request.
• To send you an offer later related to the same request. This is our legitimate interest in following up on a commercial request. You can object at any time.

How long we keep it

Form data is kept for 24 months from the last interaction, then deleted. If you become a client, the contractual terms and the tax archiving obligations apply.

3. Data from conversations with the chatbot

When the chatbot is installed on one of our clients' websites, the conversation may include: the messages written by the visitor, the contact details the visitor chooses to give (name, phone, email), the pages visited during the conversation, the IP address used to limit abuse and, if the visitor asks about an order, information about that order.

This data is processed on our client's instructions, under the contract we have with them. If you talked to a chatbot on a store and want to exercise your rights, contact that store first; we help them handle your request.

The chatbot is set up not to give out the delivery address of an order and, before giving details about an order, to check that the person asking is the one who placed it.

4. Conversations on Facebook Messenger, Instagram and WhatsApp

The businesses that use MOON Chat (our clients) can connect it to their Facebook page, their Instagram account and their WhatsApp Business numbers, through the "MOON Chat" app on the Meta platform. In that case, the chatbot replies on behalf of that business to the messages received on these channels.

Who is responsible for the data

For messages sent to a business, the data controller is the business you are writing to. FELIX ONLINE CONCEPT SRL (Tax ID 41786909, Trade Register No. J23/4628/2019) acts as a processor: it processes the data only to provide the MOON Chat service to that business and only on its instructions.

What data we receive from Meta

• your identifier in the conversation with the business's page, Instagram account or WhatsApp number (not your full account);
• your profile name, when Meta makes it available;
• on WhatsApp, your phone number;
• the content of the messages you send to the business and their date;
• the contact details you choose to write in the conversation (name, phone, email).

We don't access your friends list, your posts, other conversations or any other data in your account.

Why we use it

• to answer your questions on behalf of the business (products, stock, prices, appointments);
• to pass your request on to the business, when you ask to be contacted;
• so the business can see the conversation history and take over the conversation from the chatbot.

The legal basis is the business's legitimate interest in answering the messages you send it and, where applicable, the steps prior to a contract that you request.

What we DON'T do

• we don't sell or rent the data from these conversations;
• we don't use it for ads and we don't send it to advertising platforms;
• we don't send you unsolicited messages; on WhatsApp, the business can write to you on its own initiative only under the conditions allowed by WhatsApp's rules.

Who we share the data with

• the business you wrote to;
• Meta Platforms (Facebook, Instagram, WhatsApp), through which the messages are sent;
• the provider of the artificial intelligence model that writes the replies (Google, Gemini API), only to generate the reply;
• the infrastructure provider (Cloudflare), where the service and the data are hosted.

How long we keep it

Conversations are kept for as long as the business uses MOON Chat, but for at most 12 months after the last message, then deleted. The business can ask for earlier deletion.

How to ask for deletion

You can ask for your conversations to be deleted at any time. The steps are described on the Data deletion page.

On Telegram

Businesses can also connect their Telegram bot or their Telegram Business account to MOON Chat. The rules above apply in the same way: the controller is the business you write to, and we are the processor. From Telegram we receive the conversation identifier, your profile name, your messages and, only if you choose to send it, your phone number. Messages pass through Telegram, which processes them under its own privacy policy.

5. Google Calendar integration

Businesses that use the MOON Chat booking feature can connect their own Google Calendar from the admin dashboard. The connection is made only at the business's request, through the Google consent screen, and can be cut at any time from the dashboard ("Disconnect") or from the Google account settings.

What permissions we ask for and why

• calendar.freebusy: we only learn the time ranges when the calendar is busy, so the chatbot doesn't offer customers times that are already taken. We don't read the title, description, participants or any other details of the business's events.
• calendar.events.owned: only for calendars the business owns. We create the event for each booking made through MOON Chat (the service, the customer's name, and the phone and email they left), we move or delete it when the booking changes, and we read back only the events created by MOON Chat (tagged with a private property), so changes the business makes directly in Google Calendar also show up in the dashboard.

What we keep

• the access token provided by Google, needed for the connection, kept on our servers (Cloudflare) and used only for the operations above;
• the calendar identifier and, for each booking, the identifier of the event created;
• busy time ranges are kept only temporarily (about one minute), to calculate free times.

On disconnect, we revoke access with Google and delete the token. The bookings remain in the business's dashboard.

Limited use

MOON Chat's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In practice: Google Calendar data is used only for the booking feature visible to the business; we don't sell it, we don't use it for ads or profiling, we don't send it to artificial intelligence models, and it isn't read by people, except when the business explicitly asks us to for support, when the law requires it, or to investigate abuse or a security problem.

5.1 Protection of Google data

This section describes the concrete safeguards we use for data received through Google APIs: both Google Calendar data (section 5) and the Gmail connection described below.

What Google data we touch

• Google Calendar: busy time ranges and the events created by MOON Chat, exactly as described in section 5, for businesses that connect their calendar.
• Gmail: used only by our own team, for the company's own mailbox. We request only the gmail.send permission (sending email). We don't request and don't hold permissions to read, modify or delete email, and MOON Chat clients never connect their Gmail account to the service.

Encryption

• In transit: all connections are encrypted with TLS (HTTPS), between the browser and our servers and between our servers and the Google APIs.
• At rest: data is stored on Cloudflare infrastructure, encrypted at rest (AES-256). In addition, the OAuth tokens received from Google (refresh tokens and the app secret) are also encrypted at application level, with AES-256-GCM, using a key kept separately from the database as an application secret. Someone who saw the database couldn't use the tokens.

Access and storage

• Google tokens are never shown in the interface and never reach anyone's browser; access to the dashboard requires an account and password, with roles.
• Access to the systems that store the tokens is limited to the administrator of FELIX ONLINE CONCEPT SRL.
• Tokens are not included in backups: the daily backup explicitly excludes them. Backups are kept for at most 30 days.

Retention, deletion and revocation

• The token is kept only while the connection is active.
• On "Disconnect", the token is deleted from the database and access is revoked with Google, so nobody can use the token anymore.
• Access can also be revoked at any time directly from the Google account settings, with the same effect.

Limited Use

For all data received through Google APIs, not just calendar data: its use and transfer adhere to the Google API Services User Data Policy, including the Limited Use requirements. We don't sell this data, we don't use it for ads or profiling, we don't use it to develop or train artificial intelligence models (generalized or not), and it isn't read by people, except where we have explicit consent, the law requires it, or it's necessary for security or to investigate abuse.

6. The MOON Chat app for Shopify

Shopify stores can install MOON Chat from the Shopify App Store. In that case, the data controller is the store, and FELIX ONLINE CONCEPT SRL acts as a processor: we process the data only to provide the service to that store and only on its instructions.

What data we read from Shopify

• the catalog: products, prices, stock, photos and links, so the chatbot recommends real products;
• the store's policies and pages (returns, shipping, warranty, contact), so the chatbot answers questions correctly;
• orders, only when a shopper asks about their own order: the number, the status, the fulfillment and the tracking number. Before giving details, we check that the email or phone given in the chat matches the order. The delivery address isn't shared in the chat;
• store data: the name, domain and email address, for the MOON Chat account, notifications and service messages.

We don't ask for access to payments, card data or the store's full customer list. The subscription is paid through Shopify; we don't see payment data.

How we keep it

The access token received from Shopify is encrypted in the database (AES-256-GCM) and never reaches the browser. The data is stored on Cloudflare infrastructure. Conversations with the chatbot are kept for as long as the store uses MOON Chat, but for at most 12 months after the last message.

Uninstalling and deletion

• when the app is uninstalled, the chatbot stops immediately and the access token is deleted;
• 48 hours after uninstalling, at Shopify's request, we delete all of the store's data: the catalog, pages, conversations, stats and the account;
• during this period we may send the store a single email to find out what didn't work;
• when a shopper asks, through the store, for their data to be deleted, we delete their conversations; when they ask for a copy, we make it available to the store within 30 days at most.

7. Phone calls with MOON Voce

MOON Voce is the voice assistant that answers the phone on behalf of the businesses that use it (our clients) and, at their request, calls people who left their number. For these calls, the data controller is the business, and FELIX ONLINE CONCEPT SRL acts as a processor, as with written conversations.

At the start of each call, the assistant says that it's a virtual assistant and that the call may be recorded.

What data we process

• the phone number of the person calling or being called;
• the transcript of the conversation and the call summary;
• the details given during the call: name, phone, email, what the person wants, the booking made;
• the audio recording of the call, only if the business has turned recording on.

Why we use it

• so the assistant can answer on behalf of the business, make or move a booking and send an address or a link by text message when the person asks;
• so the business knows who called and what was agreed (the summary on Telegram or by email, the lead in its CRM) and can call back.

Who sees it

The business, in its dashboard. The MOON team can access it for support.

Who we share the data with

• Twilio: telephony and text messages; the audio recording also stays with Twilio, when the business turns it on;
• Google (Gemini API): the assistant's voice and the transcription;
• ElevenLabs: voice and transcription, only when the business chooses the premium voice;
• Cloudflare: storage of transcripts, summaries and call data.

How long we keep it

The same as other conversations: for as long as the business uses the service, but for at most 12 months after the last call, then deleted. The business can ask for earlier deletion. To exercise your rights, contact the business you called first; we help them handle your request.

The demo on the Voice assistant page

On the Voice assistant page you can talk from your browser with the assistant of a test clinic. Here we are the controller.

• the microphone is used only for the duration of the test call and stops when you hang up;
• the test conversation is saved and may be read by the MOON team to improve the assistant; it's kept like other conversations, for at most 12 months;
• the test call isn't recorded as audio; your voice passes through Google (Gemini API) and Cloudflare so the assistant can reply;
• for the test call limit, we keep only a fingerprint (hash) of the IP address in the database;
• the clinic is a test one, so there's no need to give real details.

The legal basis is your request to try the demo and our legitimate interest in improving the service.

8. Who we share data with

We don't sell data. We share it only with the providers the service depends on:

• Cloudflare, Inc.: hosting of the application and the database;
• Google LLC: the language models that generate the chatbot's replies; the conversation content and the catalog excerpt needed for the reply pass through them; for calls, the assistant's voice and the transcription (section 7); separately, Google Calendar, only for businesses that connect it (section 5);
• Twilio: telephony and text messages for calls (section 7);
• ElevenLabs: the voice for calls, only when the business chooses the premium voice (section 7);
• Resend: sending email notifications;
• Telegram: messages, for businesses that connect their Telegram bot, and Telegram notifications, for businesses that choose them;
• the client's e-commerce platform (Gomag, WooCommerce, Shopify and others): when an order status is checked;
• accounting and authorities, to the extent the law requires.

The content of conversations with the chatbot is not shared with advertising platforms and isn't used to target ads.

Some of these providers may process data outside the European Economic Area, based on the standard contractual clauses approved by the European Commission.

9. Advertising and measurement

We promote our service through paid ads. If you accepted marketing cookies on this website, the tools below may receive the information that you visited a page or submitted the form, together with an identifier from your browser:

• Meta Platforms (Facebook, Instagram): measuring campaign results and showing ads;
• TikTok: the same purposes;
• Google (Google Ads, Google Analytics): measuring traffic and campaigns;
• OpenAI: when we advertise through ads shown in ChatGPT conversations, the platform may report campaign results.

These tools are turned on only after your consent and can be refused with no consequences for your use of the website. The legal basis for processing is consent, which you can withdraw at any time from your browser's cookie settings or by writing to us. The data sent is limited to the browsing event and doesn't include the content of conversations with the chatbot.

10. Security

The chatbot's access is restricted to the client's domain. Traffic is limited per visitor and per store. Access keys to clients' platforms never reach the visitor's browser. Content entered by visitors is treated as untrusted and filtered before it's shown in the dashboard. Access to the dashboard requires a username and password. The full measures and the incident procedure are on the Security and incident response page.

11. Your rights

You have the right of access, rectification, erasure, restriction of processing, portability, objection, and the right to withdraw your consent where consent is the legal basis. You can exercise your rights by writing to us at the contact details above; we reply within 30 days at most.

If you're not satisfied with our reply, you can contact the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP): dataprotection.ro.

12. Minors

The service is aimed at legal entities and isn't intended for minors. We don't knowingly collect data from people under 16.

13. Changes

We may update this policy. The version in force is the one published here, with the update date shown at the top.