Last updated 22 September 2026
Privacy Policy
This Privacy Policy explains how Salt Agents processes personal data in operating Salts. It is issued under Articles 13 and 14 of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), and section 12 sets out the additional disclosures required of a business by the California Consumer Privacy Act as amended by the CPRA (Cal. Civ. Code §1798.100-199).
1. Controller and contact details
We are responsible for the data described here. These are the addresses to use.
- 1.1The controller for the processing described in this Policy is Salt Agents, [REGISTERED ADDRESS — VERIFY] (Art. 13(1)(a) GDPR).
- 1.2Our data protection officer may be contacted at [DATA PROTECTION OFFICER — VERIFY, or not appointed] (Art. 13(1)(b) GDPR).
- 1.3Requests under this Policy, including data subject requests, should be sent to privacy@[DOMAIN].
2. Scope and your own controllership
This Policy covers the service we run. Where other people message your Agent, you are the controller and we act for you.
- 2.1This Policy applies to the hosted service we operate at [DOMAIN]. It does not apply to a deployment you host yourself, nor to any Connected Service, each of which publishes its own policy.
- 2.2Where you create an Agent that receives messages from individuals other than yourself, you determine the purposes and means of that processing. You are the controller of that content and we act as your processor under Article 28 GDPR, processing it only on your documented instructions. The obligation to inform those individuals under Articles 13 and 14 GDPR rests with you.
3. Categories of personal data processed
Your email, your Agent's settings and keys, everything sent to the Agent, and what each reply cost.
- 3.1We process the categories of personal data set out below. Personal data is obtained directly from you, except where the source column states otherwise (Art. 13 and Art. 14(2)(f) GDPR).
- 3.2Provision of account data and of the Credentials an Agent requires is a contractual requirement: without them we cannot create an Account or operate an Agent, and the Service cannot be provided (Art. 13(2)(e) GDPR).
Data categories, examples and source
| Category | Data | Source |
|---|---|---|
| Account data | Email address, authentication identifiers and session metadata; the access list and administrator of each Agent | You; our authentication provider |
| Agent configuration | Agent name, selected model, system prompt, tuning parameters, enabled capabilities | You |
| Credentials | OpenRouter API key, Telegram bot token and username, search API key, MCP server URLs and headers | You |
| Conversation content | Messages, attachments (documents, images, audio), text extracted from attachments, and facts saved to memory where that capability is enabled | You and anyone you permit to message the Agent |
| Telegram data | Chat, user and forum-topic identifiers, usernames, and the whitelists you configure | Telegram, on receipt of a message |
| Usage records | Tokens consumed, cost in USD, latency and timestamp per reply | Generated by the Service |
| Technical data | IP address, request metadata, error diagnostics and security logs | Generated automatically on each request |
Category
Account data
Data
Email address, authentication identifiers and session metadata; the access list and administrator of each Agent
Source
You; our authentication provider
Category
Agent configuration
Data
Agent name, selected model, system prompt, tuning parameters, enabled capabilities
Source
You
Category
Credentials
Data
OpenRouter API key, Telegram bot token and username, search API key, MCP server URLs and headers
Source
You
Category
Conversation content
Data
Messages, attachments (documents, images, audio), text extracted from attachments, and facts saved to memory where that capability is enabled
Source
You and anyone you permit to message the Agent
Category
Telegram data
Data
Chat, user and forum-topic identifiers, usernames, and the whitelists you configure
Source
Telegram, on receipt of a message
Category
Usage records
Data
Tokens consumed, cost in USD, latency and timestamp per reply
Source
Generated by the Service
Category
Technical data
Data
IP address, request metadata, error diagnostics and security logs
Source
Generated automatically on each request
4. Purposes and legal bases
Each purpose and the GDPR ground we rely on for it.
- 4.1We process personal data for the purposes and on the legal bases set out below (Art. 13(1)(c) GDPR). Where we rely on Article 6(1)(f), the legitimate interest pursued is stated (Art. 13(1)(d) GDPR).
- 4.2We do not sell personal data, do not use conversation content for advertising or profiling, and do not use it to train models of our own.
Processing purposes and legal bases
| Purpose | Data | Legal basis |
|---|---|---|
| Creating and authenticating an Account | Account data | Art. 6(1)(b) — performance of a contract |
| Operating an Agent: storing conversations, routing model calls, delivering Telegram messages, running enabled capabilities | Agent configuration, Credentials, conversation content, Telegram data | Art. 6(1)(b) — performance of a contract |
| Showing what each reply cost | Usage records | Art. 6(1)(b) — performance of a contract |
| Maintaining security and availability, preventing abuse, diagnosing faults | Technical data, usage records | Art. 6(1)(f) — legitimate interest in operating a secure and functioning service |
| Responding to requests and enquiries | Account data, correspondence | Art. 6(1)(b) and Art. 6(1)(f) — legitimate interest in responding |
| Complying with legal obligations and responding to lawful requests | Any of the above | Art. 6(1)(c) — legal obligation |
Purpose
Creating and authenticating an Account
Data
Account data
Legal basis
Art. 6(1)(b) — performance of a contract
Purpose
Operating an Agent: storing conversations, routing model calls, delivering Telegram messages, running enabled capabilities
Data
Agent configuration, Credentials, conversation content, Telegram data
Legal basis
Art. 6(1)(b) — performance of a contract
Purpose
Showing what each reply cost
Data
Usage records
Legal basis
Art. 6(1)(b) — performance of a contract
Purpose
Maintaining security and availability, preventing abuse, diagnosing faults
Data
Technical data, usage records
Legal basis
Art. 6(1)(f) — legitimate interest in operating a secure and functioning service
Purpose
Responding to requests and enquiries
Data
Account data, correspondence
Legal basis
Art. 6(1)(b) and Art. 6(1)(f) — legitimate interest in responding
Purpose
Complying with legal obligations and responding to lawful requests
Data
Any of the above
Legal basis
Art. 6(1)(c) — legal obligation
5. Recipients and sub-processors
Cloudflare hosts it, Clerk signs you in, OpenRouter routes the model call, Telegram carries the chat.
- 5.1We disclose personal data to the categories of recipient listed below (Art. 13(1)(e) GDPR). Each processor acts under a written contract incorporating the terms required by Article 28(3) GDPR.
- 5.2You authorise these sub-processors generally under Article 28(2) GDPR. We will give notice within the Service or by email before adding or replacing a sub-processor, and you may object by writing to privacy@[DOMAIN] within 30 days; where an objection cannot be accommodated, you may terminate by deleting the affected Agent.
- 5.3Content sent to a Model Provider or a Connected Service is processed by that party under its own terms. Some Model Providers use inputs and outputs to improve their models; where that matters to you, select a provider whose terms exclude it. An MCP server you connect is a third party of your choosing, which we do not vet.
- 5.4We may also disclose personal data where required by law, court order or a binding request from a competent authority, and to a successor entity in connection with a merger, acquisition or sale of assets, in which case we will notify you.
Sub-processors and recipients
| Recipient | Purpose | Location [VERIFY] |
|---|---|---|
| Cloudflare, Inc. | Hosting, storage, network and edge compute | United States; global edge |
| Clerk, Inc. | Authentication and session management | United States |
| OpenRouter, Inc. | Routing each model call to the Model Provider you selected, under your own API key | United States |
| Model Providers | Generating the Output for a call routed by OpenRouter; identity depends on the model you select | Varies by provider |
| Telegram Messenger Inc. | Delivering messages to and from a bot you connect | Varies; see Telegram's policy |
| Brave Software, Inc., or a SearXNG instance you nominate | Executing a web search where that capability is enabled | United States; or as you configure |
| MCP servers you connect | Executing tool calls you have configured; recipient and location determined by you | As you configure |
Recipient
Cloudflare, Inc.
Purpose
Hosting, storage, network and edge compute
Location [VERIFY]
United States; global edge
Recipient
Clerk, Inc.
Purpose
Authentication and session management
Location [VERIFY]
United States
Recipient
OpenRouter, Inc.
Purpose
Routing each model call to the Model Provider you selected, under your own API key
Location [VERIFY]
United States
Recipient
Model Providers
Purpose
Generating the Output for a call routed by OpenRouter; identity depends on the model you select
Location [VERIFY]
Varies by provider
Recipient
Telegram Messenger Inc.
Purpose
Delivering messages to and from a bot you connect
Location [VERIFY]
Varies; see Telegram's policy
Recipient
Brave Software, Inc., or a SearXNG instance you nominate
Purpose
Executing a web search where that capability is enabled
Location [VERIFY]
United States; or as you configure
Recipient
MCP servers you connect
Purpose
Executing tool calls you have configured; recipient and location determined by you
Location [VERIFY]
As you configure
6. Credentials
Keys are stored so the Agent can use them, never displayed back to you, and removable at any time.
- 6.1Credentials must be usable at the time of a call and are therefore stored in recoverable form rather than as a one-way hash. They are held with the configuration of the Agent they belong to, are never returned in full to a browser — the settings interface displays a mask — and are removed from storage when the field is cleared or the Agent is deleted.
- 6.2Removal from our storage does not revoke a Credential at its issuer. We recommend scoping each Credential narrowly, setting a spending limit on your OpenRouter account, and rotating any Credential you believe may be compromised.
7. International transfers
Data leaves your country, because our providers and the model providers are global.
- 7.1Personal data is transferred to, and processed in, countries outside the European Economic Area and the United Kingdom, including the United States (Art. 13(1)(f) GDPR).
- 7.2Where a transfer is made to a country not covered by an adequacy decision of the European Commission under Article 45 GDPR, we rely on the standard contractual clauses adopted by the Commission under Article 46(2)(c) GDPR, supplemented where necessary by additional technical and organisational measures. A copy of the safeguards applying to a given recipient is available on request to privacy@[DOMAIN].
- 7.3A transfer to a Connected Service you configure, including an MCP server, is made on your instruction and under the transfer mechanism, if any, of that provider.
8. Retention
We keep things until you delete them; deleting an Agent deletes its contents.
- 8.1Personal data is retained in accordance with the schedule below and thereafter deleted or irreversibly anonymised (Art. 5(1)(e) and Art. 13(2)(a) GDPR).
- 8.2Deleting a session deletes its messages, attachments and usage records. Deleting an Agent deletes its configuration, Credentials, sessions and memories. Deleting your Account deletes the Agents you administer.
- 8.3Following deletion, residual copies may persist in encrypted backups and in provider logs until overwritten in the ordinary cycle, which is up to 30 days [VERIFY against provider commitments]. Data we are required to retain for a legal purpose is retained for the period of that requirement and processed for no other purpose.
Retention schedule
| Category | Retention period | Trigger |
|---|---|---|
| Account data | Life of the Account | Account deletion |
| Agent configuration and Credentials | Life of the Agent, or until the field is cleared | Agent deletion |
| Conversation content and attachments | Until the session or Agent is deleted; no automatic expiry | Session or Agent deletion |
| Memories | Until deleted by you or the Agent is deleted | Agent deletion |
| Usage records | Life of the session | Session deletion |
| Technical and security logs | [VERIFY — provider default, typically 30 days] | Elapse of the retention window |
| Backups | Up to 30 days after deletion | Backup rotation |
Category
Account data
Retention period
Life of the Account
Trigger
Account deletion
Category
Agent configuration and Credentials
Retention period
Life of the Agent, or until the field is cleared
Trigger
Agent deletion
Category
Conversation content and attachments
Retention period
Until the session or Agent is deleted; no automatic expiry
Trigger
Session or Agent deletion
Category
Memories
Retention period
Until deleted by you or the Agent is deleted
Trigger
Agent deletion
Category
Usage records
Retention period
Life of the session
Trigger
Session deletion
Category
Technical and security logs
Retention period
[VERIFY — provider default, typically 30 days]
Trigger
Elapse of the retention window
Category
Backups
Retention period
Up to 30 days after deletion
Trigger
Backup rotation
9. Security
Encryption in transit, per-Agent isolation, and access checked on every request.
- 9.1We implement technical and organisational measures appropriate to the risk, as required by Article 32 GDPR, including encryption of personal data in transit, isolation of each Agent's storage, authentication of every request against a cryptographically signed session token, and authorisation against the Agent's access list, which is held separately from the configuration it governs.
- 9.2No system is perfectly secure. Where a personal data breach occurs, we will notify the competent supervisory authority in accordance with Article 33 GDPR and affected individuals in accordance with Article 34 GDPR where the thresholds are met.
10. Your rights
Access, rectification, erasure, restriction, portability, objection. Email us; we answer within 30 days.
- 10.1Subject to the conditions in the GDPR, you have the right to request access to your personal data (Art. 15), its rectification (Art. 16), its erasure (Art. 17), restriction of processing (Art. 18) and portability of data you provided to us (Art. 20), and to object to processing based on Article 6(1)(f) (Art. 21). We extend these rights to all users as a matter of policy, wherever they reside.
- 10.2Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal (Art. 13(2)(c) GDPR).
- 10.3Many of these rights are exercisable directly: settings display and amend your configuration, sessions may be exported and deleted, and deleting an Agent erases its contents. For anything else, write to privacy@[DOMAIN]. We respond within one month of receipt and may extend that period by two further months where the request is complex, notifying you of the extension and its reasons (Art. 12(3) GDPR).
- 10.4You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Art. 13(2)(d) and Art. 77 GDPR). Our lead supervisory authority is [LEAD SUPERVISORY AUTHORITY — VERIFY].
- 10.5We do not carry out automated decision-making producing legal or similarly significant effects, or profiling, within the meaning of Article 22 GDPR. An Output is generated automatically but produces no decision of that character; what you do with it is your own decision (Art. 13(2)(f) GDPR).
- 10.6We do not process personal data for any purpose other than those stated in section 4. Should we intend to do so, we will inform you beforehand and provide the information required by Article 13(3) GDPR.
12. California residents
We collect the categories below, sell nothing, share nothing for advertising, and will not penalise you for asking.
- 12.1This section applies to California residents and supplements the rest of this Policy. Terms used have the meanings given in Cal. Civ. Code §1798.140.
- 12.2In the twelve months preceding the date of this Policy we collected the categories of personal information set out below, for the business purposes described in section 4, from the sources described in section 3, and disclosed them for a business purpose to the recipients listed in section 5.
- 12.3We do not sell personal information (§1798.140(ad)) and do not share it for cross-context behavioural advertising (§1798.140(ah)). We have not done so in the preceding twelve months, including in respect of consumers under 16 years of age. No "Do Not Sell or Share My Personal Information" link is therefore required.
- 12.4We collect the contents of your communications with an Agent, which constitutes sensitive personal information under §1798.140(ae)(1)(D). We use it solely to provide the Service you requested, which is a permitted purpose under §1798.121(a), and we do not use or disclose it to infer characteristics about you.
- 12.5You have the right to know (§§1798.100, 1798.110, 1798.115), to delete (§1798.105), to correct (§1798.106), to limit the use of sensitive personal information (§1798.121), to opt out of sale or sharing (§1798.120) and to non-discrimination for exercising any of them (§1798.125). Submit a request to privacy@[DOMAIN]; we confirm receipt within 10 business days and respond within 45 calendar days, extendable once by a further 45 days where reasonably necessary.
- 12.6An authorised agent may submit a request on your behalf with written permission signed by you, and we may require you to verify your identity directly. We verify requests by reference to control of the email address on the Account.
Categories collected in the preceding 12 months (§1798.140(v))
| Statutory category | Collected | Examples |
|---|---|---|
| Identifiers | Yes | Email address, account identifier, IP address |
| Commercial information | No | — |
| Biometric information | No | — |
| Internet or other electronic network activity | Yes | Request metadata, feature usage, error logs |
| Geolocation data | No | Precise geolocation is not collected; IP address may imply coarse region |
| Audio, electronic, visual or similar information | Yes | Voice notes and images you attach to a message |
| Professional or employment information | No | Only where you choose to put it in a message |
| Education information | No | — |
| Inferences | No | We draw no profile from your data |
| Sensitive personal information | Yes | Contents of your communications with an Agent (§1798.140(ae)(1)(D)); account credentials held by our authentication provider |
Statutory category
Identifiers
Collected
Yes
Examples
Email address, account identifier, IP address
Statutory category
Commercial information
Collected
No
Examples
—
Statutory category
Biometric information
Collected
No
Examples
—
Statutory category
Internet or other electronic network activity
Collected
Yes
Examples
Request metadata, feature usage, error logs
Statutory category
Geolocation data
Collected
No
Examples
Precise geolocation is not collected; IP address may imply coarse region
Statutory category
Audio, electronic, visual or similar information
Collected
Yes
Examples
Voice notes and images you attach to a message
Statutory category
Professional or employment information
Collected
No
Examples
Only where you choose to put it in a message
Statutory category
Education information
Collected
No
Examples
—
Statutory category
Inferences
Collected
No
Examples
We draw no profile from your data
Statutory category
Sensitive personal information
Collected
Yes
Examples
Contents of your communications with an Agent (§1798.140(ae)(1)(D)); account credentials held by our authentication provider
13. Children
The Service is not for anyone under 16.
- 13.1The Service is not directed at children and may not be used by anyone under 16 years of age [VERIFY against the age set under Art. 8(1) GDPR in your Member State, which may be as low as 13]. We do not knowingly collect personal data from children under that age.
- 13.2Where you operate an Agent in a conversation that may include children, you are responsible as controller for any consent required. If you believe a child's personal data has reached us, write to privacy@[DOMAIN] and we will delete it without undue delay.
14. Self-hosted deployments
Host it yourself and this Policy does not apply — you become the controller.
- 14.1Salts may be deployed on infrastructure you control. In that case personal data does not reach our systems, we are neither controller nor processor in respect of it, and this Policy does not apply. The providers listed in section 5 continue to process data under the accounts you configure, and you are the controller in respect of that processing.
15. Changes to this Policy
We date each version and tell you when a change is material.
- 15.1We may amend this Policy. The "Last updated" date identifies the current version. Where an amendment materially affects the processing of your personal data, we will notify you within the Service or by email before it takes effect.
16. Contact and complaints
Where to write, and who to complain to if we get it wrong.
- 16.1Salt Agents, [REGISTERED ADDRESS — VERIFY]. Data protection officer: [DATA PROTECTION OFFICER — VERIFY, or not appointed].
- 16.2Privacy and data subject requests: privacy@[DOMAIN]. Other enquiries: support@[DOMAIN].
- 16.3You may lodge a complaint with [LEAD SUPERVISORY AUTHORITY — VERIFY] or with the supervisory authority of your habitual residence. We would ask that you raise the matter with us first.