Privacy Policy
1. Introduction
This Privacy Policy ("Policy") describes how SENDSOFT LTD, a company incorporated under the laws of the Republic of Cyprus, registration number ΗΕ 433823, with its registered office at Agias Fylaxeos, 131, Flat/Office 301, 3083 Limassol, Cyprus ("Sendsoft", "we", "our", or "us"), collects, uses, stores, and shares information when you use Kisei AI (the "Service").
Kisei AI is an AI assistant that operates through the Telegram messaging platform and integrates with third-party productivity services, including Google Workspace services such as Gmail, Google Calendar, Google Drive, and Google Sheets.
This Policy applies to all users of the Service. By using the Service, you acknowledge that you have read and understood this Policy.
If you do not agree with this Policy, you must not use the Service.
2. Information We Collect
2.1. Account information
When you access the Service, we collect a unique identifier and display name from the messaging platform through which you access the Service. We do not collect your phone number, real name, or government-issued identifiers unless you explicitly provide them.
2.2. Content you provide
We process the messages, files, voice recordings, and other content you submit to the Service in order to generate responses and perform the actions you request.
2.3. Contextual memory
To provide a coherent experience across sessions, the Service stores structured contextual data ("Memory") derived from your interactions. Memory consists of facts, preferences, and references that you explicitly or implicitly ask the Service to remember.
2.4. Information from connected third-party services
When you connect a third-party service to the Service (such as Google Workspace, Notion, or others), the Service accesses data from that third-party service only to the extent necessary to perform the actions you request. Specific data accessed from Google services is described in Section 4.
2.5. Technical data
We automatically collect technical data necessary for the operation of the Service, including timestamps, error logs, and metadata about your usage patterns. This data is not linked to the content of your messages.
3. How We Use Information
We use the information collected for the following purposes:
- To provide, maintain, and operate the Service.
- To process your requests and execute actions you initiate within connected third-party services.
- To maintain context across your sessions through the Memory feature.
- To improve the reliability, security, and performance of the Service.
- To detect, prevent, and address technical issues, abuse, or violations of our Terms of Service.
- To comply with applicable legal obligations.
We do not use your information for advertising. We do not sell your information to third parties.
4. Google User Data
This section describes how the Service accesses, uses, stores, and shares data obtained from Google APIs. This section is provided to comply with the Google API Services User Data Policy.
4.1. Limited Use Disclosure
Kisei AI's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Specifically, we comply with the following restrictions:
- We use Google user data only to provide or improve user-facing features that are prominent in the Service.
- We do not use Google user data for serving advertisements.
- We do not transfer Google user data to third parties except as necessary to provide or improve user-facing features of the Service, to comply with applicable law, or as part of a merger, acquisition, or sale of assets with notice to users.
- We do not allow humans to read Google user data unless we have obtained your explicit consent for specific messages, it is necessary for security purposes (such as investigating abuse), to comply with applicable law, or for internal operations where the data has been aggregated and anonymized.
- We do not use Google user data to develop, improve, or train generalized or non-personalized AI and/or machine learning models.
4.2. Google services accessed
The Service requests authorization to access the following Google services through OAuth 2.0:
| Service | Scope | Purpose |
|---|---|---|
| Gmail | gmail.modify | To read, search, organize, and modify the labels of emails when you instruct the Service to manage your inbox. |
| Gmail | gmail.send | To send emails on your behalf, only after you have reviewed and confirmed the draft. |
| Gmail | gmail.compose | To create and save email drafts in your Gmail account. |
| Google Calendar | calendar | To create, view, modify, and delete events when you instruct the Service to manage your schedule. |
| Google Drive | drive.file | To access files that you explicitly open with or create through the Service. |
| Google Sheets | spreadsheets | To read and modify spreadsheets that you explicitly authorize the Service to access. |
| Basic profile | userinfo.email, userinfo.profile, openid | To identify your account and display your email address in the Service interface. |
4.3. How Google user data is processed
Google user data is processed only at your explicit request. The Service does not perform background or automated processing of your Gmail, Calendar, Drive, or Sheets data outside of actions you initiate.
Email content accessed via Gmail is processed in memory for the duration of generating a response and is not stored persistently except as Memory items that you explicitly ask the Service to remember.
Outgoing emails are presented to you as drafts for your review and confirmation before being sent. The Service does not send emails on your behalf without your explicit confirmation.
4.4. Revoking access
You may revoke the Service's access to your Google account at any time by visiting your Google Account permissions page at https://myaccount.google.com/permissions and removing access for Kisei AI.
Revocation will immediately terminate the Service's ability to access your Google data. Any previously processed data that has been stored as Memory in the Service will remain until you delete it through the Service's data management features.
5. How We Share Information
We do not sell your personal information. We do not share your personal information with third parties for marketing or advertising purposes.
We share information only with the following categories of recipients, and only to the extent necessary to operate the Service:
| Recipient | Data shared | Purpose |
|---|---|---|
| DeepSeek | Message content and context required for AI processing | To generate AI responses |
| OpenAI, L.L.C. | Audio recordings and text for speech processing; message content and context required for AI processing | To generate AI responses and provide speech processing (text-to-speech generation, speech-to-text re-recognition and text polishing) |
| Hetzner Online GmbH | All stored data (as infrastructure provider) | Hosting of the Service infrastructure |
| Telegram FZ-LLC | Messages routed through the messaging platform | Message delivery between you and the Service |
All other models used by the Service are deployed locally on our infrastructure and do not receive user data. We have entered into Data Processing Agreements with each of the above subprocessors where required by applicable law.
We may disclose information when required by law, by court order, or by a binding request from a competent governmental authority.
6. Data Storage and Security
Data is stored on servers operated by Hetzner Online GmbH, located in the Federal Republic of Germany.
We implement appropriate technical and organizational measures to protect your information, including:
- Encryption of data at rest on storage systems.
- Encryption of data in transit using TLS 1.3.
- Access controls limiting employee access to user data on a need-to-know basis.
- Two-factor authentication for personnel with administrative access.
- Regular security audits and vulnerability assessments.
No system is completely secure. In the event of a data breach affecting your personal information, we will notify you in accordance with applicable law, including within 72 hours where required under the General Data Protection Regulation (Regulation (EU) 2016/679).
7. Data Retention
| Category of data | Retention period |
|---|---|
| Message content | Duration of your use of the Service |
| Contextual memory (user-managed) | Until you delete it or your account is closed |
| OAuth tokens for connected services | Until you revoke access or close your account |
| Google user data accessed via API | Not retained beyond fulfillment of your request, unless saved by you as Memory |
| Technical logs without content | 90 days |
| Content logs for debugging | 30 days |
| Backups after account deletion | 30 days |
After the applicable retention period, data is either deleted or anonymized.
8. Your Rights
Subject to applicable law, you have the following rights with respect to your personal information:
- Right of access: You may request a copy of the personal information we hold about you.
- Right to rectification: You may request that we correct inaccurate or incomplete information.
- Right to erasure: You may request that we delete your personal information, subject to certain exceptions.
- Right to restriction of processing: You may request that we limit the processing of your information.
- Right to data portability: You may request a copy of your information in a structured, commonly used, and machine-readable format.
- Right to object: You may object to processing based on our legitimate interests.
- Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time.
- Right to lodge a complaint: You may lodge a complaint with a data protection authority, including the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus (dataprotection.gov.cy).
To exercise any of these rights, contact us at privacy@kisei.ai. We will respond to your request within 30 days.
9. International Data Transfers
Personal information processed by us may be transferred to, stored, and processed in jurisdictions outside of your country of residence.
Where personal information is transferred outside the European Economic Area, we rely on appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure that your personal information receives an adequate level of protection.
10. Children's Privacy
The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will delete that information promptly.
11. Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will notify you through the Service and update the "Last updated" date at the top of this Policy. Continued use of the Service after such changes constitutes acceptance of the updated Policy.
12. Telegram Platform
The Service operates on the Telegram platform. This Policy applies in addition to the Telegram Bot Platform Developer Terms of Service and the Telegram Privacy Policy. In the event of any conflict between this Policy and those Telegram documents, the Telegram documents shall prevail.
The Service is an independent product operated by us and is not maintained, endorsed by, or affiliated with Telegram Messenger Inc. We are solely responsible for the processing of your personal data within the Service.
When you interact with the Service through Telegram, Telegram may transmit to us certain account data as described in the Telegram Privacy Policy, including your Telegram user identifier, username, and profile information. Any data you share with the Service is governed by this Policy, while data handled by Telegram itself remains subject to the Telegram Privacy Policy.
13. Contact Us
If you have questions about this Policy or our data practices, please contact us:
SENDSOFT LTD
Agias Fylaxeos, 131, Flat/Office 301, 3083 Limassol, Cyprus
Email: privacy@kisei.ai
Website: https://dev.kisei.ai/