Privacy Policy

The controller for the processing described here, within the meaning of Art. 4(7) GDPR, is:

Controller

Farooq Quraishi, trading as Serlion (Einzelunternehmen)

Data protection

legal@serlion.com

Supervisory authority

Der Hessische Beauftragte für Datenschutz und Informationsfreiheit

Our full postal address is in the Impressum. Data protection enquiries reach us fastest by email.

We are below the threshold in § 38 BDSG that would require a designated Data Protection Officer. Data protection enquiries go to the address above.

Two different relationships run through this product, and they have different answers.

In practice: if you subscribe to Serlion, this policy covers your account. If you typed a message into a Serlion widget on somebody else's website, or wrote to a business on Telegram, WhatsApp, LINE, Discord or email and Serlion answered, that business decides what happens to it, and your rights are exercised against them rather than against us. We act only on their instructions.

Paid plans add one more party. Stripe, through its Managed Payments service (shown to you as “Sold through Link”), is the seller of record for the payment. It decides for itself how it uses what you enter at checkout and is responsible for that under its own privacy notices: link.com/privacy and stripe.com/privacy. It also works for us as a processor for the billing records of your subscription in our Stripe account. Section 06 lists it.

Account and billing data

• Your name, company name and business email address.
• A password hashed with bcrypt, or a verified identity token if you sign in with Google. We never receive your Google password.
• Your plan and billing history: the plan, its price and billing period, the dates of a trial, renewal, cancellation or failed payment, and the customer and subscription numbers Stripe gives us. Payment details, such as a card number, are handled entirely by Stripe and never reach our servers.
• When you buy a paid plan: what you enter at checkout (name, billing address, tax details, payment details) is collected by Stripe’s Managed Payments service, which sells the subscription to you as the seller of record (shown to you as “Sold through Link”) and handles that data for itself under its own privacy notices.
• What Stripe passes on to us for your subscription: your billing name, country and address, tax details, how you paid (for a card, its brand and last four digits), the status of each payment, and your invoices and receipts.
• What we send to Stripe: your business email address, an internal account number, and the plan you chose (its name, billing period, price and, on Custom, its limits). Nothing about your conversations or your visitors.
• If you ask the payment provider to delete your payment data, it cancels your subscription and removes the related records from our Stripe account. Your plan then ends and your account moves to Free. The rest of your Serlion account stays until you close it.
• If you or a team member connect Telegram alerts: that person’s Telegram account ID and username, so the alerts bot knows where to send them.
• If you close your account and answer the short exit survey: your answers. Your company name and email address are removed from them after 30 days.
• On Bring Your Own Key plans, the provider API key you connect. It is encrypted with AES-256-GCM before it reaches the database, decrypted only in memory at the moment a request is made, and never appears in an API response, a dashboard view or a log file.
• If you use Serlion Agent: the access details you enter to connect your shop, Cal.com, Stripe account or Slack. They are encrypted with AES-256-GCM before they reach the database and decrypted only in memory when a request to that service is made.

Conversation data from your visitors and connected channels

• Messages a visitor types and the replies generated for them. The assistant can ask for contact details, for example to pass on a message or to book a meeting, and you can add a pre-chat form that asks for a name, email address and phone number. Beyond that, only what the visitor types is processed.
• Files a visitor attaches, if you have enabled attachments.
• A star rating and a comment, if the visitor leaves them. The email address a visitor gives to receive a transcript or a follow-up reply. If you use a consent checkbox: the wording shown, and the time and page on which the visitor ticked it.
• If your website passes the signed-in user to the widget (the identify call): that user’s ID, name and email address.
• If you connect chat channels: messages from people who write to you on Telegram, WhatsApp, LINE, Discord or email, your replies, and the details those services pass along with each message (a display name or username; a phone number on WhatsApp; the sender’s address on email).
• A sentiment signal derived from each conversation, which produces the analytics in your dashboard.
• Knowledge-base content you supply — URLs, documents, product and FAQ material — used only to answer questions about your own business. To make it searchable, its text is sent to OpenAI (section 06).

Serlion Agent, if you switch it on

• What a customer types into the widget on your website, and the replies.
• What a customer gives to identify an order, a booking or a subscription (an order number, an email address), and what your connected shop, calendar or Stripe account returns for it. For an order that is its status, items, total, tracking and the delivery city and country. The full delivery address is read only after the customer has typed a 6-digit code that was emailed to the address on the order.
• To write its answers, the assistant sends the text of the chat, and the order, booking or subscription details it needs, to the AI provider (section 06 on Managed plans, your own provider on Bring Your Own Key plans). We do not use it to train models.
• Whether the customer confirmed or declined each proposed change, and the steps taken, so that you can review every chat in your activity view.
• The 6-digit confirmation codes. They are stored only as a hash and stop working after ten minutes.
• With each confirmed refund or cancel, a one-way code made from the order’s email address (not the address itself). We use it to count repeat refunds for the same customer, and it is deleted together with the chat.
• Requests a customer sends to your team: the name, contact details and message typed into the request form.
• A random visitor ID kept in the customer’s browser, and daily counters made from a hash of that ID and of the customer’s IP address. They are used only to apply the daily fairness limit.

Chatting with Serlion on serlion.com

• serlion.com has its own chat assistant, built with Serlion. If you use it, we process what you type and the assistant’s replies, and we send that text to our AI providers (section 06) to write each answer. The conversation is kept like any other conversation on a Pro plan (section 05). Please do not type passwords, card numbers or anything else you would not want an AI provider to see.
• The Persona Playground on this website lets you try assistant styles. What you type there is sent to one of our AI providers (section 06) to write the reply. We do not store it.
• If you leave your name, email address or phone number, we use it only to reply to your enquiry.
• Like on any customer’s website, the chat widget keeps a few items in your browser (see section 13).

Technical data

• IP address, browser and device information, referring page and access timestamps.
• Your IP address is also held in the server’s memory for a short time, to apply the rate limits and sign-in lockouts that stop abuse. These counters are not written to our database. They are forgotten when their time window ends or when the server restarts.
• Your IP address and browser details also reach Google in two cases: the sign-in and sign-up pages load Google’s sign-in script and button, and the pages of Lanus Agent (lanus.serlion.com) load their typefaces from Google Fonts. serlion.com and your dashboard serve their typefaces from our own servers. Nothing else is loaded from Google.
• Response times, error rates and which provider served a given request, used to keep the service fast and to diagnose faults.

We do not use any of this to build advertising profiles, and we do not use your conversations or knowledge-base content to train AI models.

Deletion is enforced by a scheduled sweep, not by policy alone. The same windows apply to Lanus Agent. You can also delete an individual conversation from your dashboard at any time. It is removed from our database at once rather than waiting for the sweep; copies in file storage, in Lanus Agent and in the tools you have connected are deleted in the background.

Each provider in the first three groups below processes data only on our instructions and under a data processing agreement. There are two exceptions. Stripe decides for itself how it uses what you enter at checkout (see its row and the note under “Running the business”). Google receives your IP address and browser details straight from your browser when a page loads its sign-in button or typefaces, and decides for itself how to use them (see its row). The last group is made up of services you connect with your own account; its note explains how they differ. We keep this list complete and current. If we add one, section 15 explains how you will hear about it.

Storage

Your account data and your conversation history are stored in Germany, and that storage does not leave the EU.

Files

Files a visitor attaches, and the logo you upload, are stored separately in Cloudflare R2; where a bucket is not pinned to an EU location, that storage may sit outside the EU and rests on the transfer basis listed for Cloudflare in section 06. An attached file is reached by a long random link, and anyone who has the link can open the file without signing in.

When data moves

Transfers otherwise happen when a request is sent to a provider in section 06 that is based outside the EU.

Legal basis

Those transfers rest on EU Standard Contractual Clauses under Art. 46(2)(c) GDPR, or on the EU–US Data Privacy Framework where the provider is certified under it. The basis for each provider is listed in section 06.

Managed plans

On Managed plans, every provider we route to is covered by one of those mechanisms.

Services you connect

Data sent to a chat channel, team alert destination or other service you connect with your own account (the last group in section 06) goes there under your own agreement with that provider.

On BYOK plans you supply your own API key and choose your own provider.

Currently selectable

Groq, OpenAI, Google, Anthropic, Together AI, Fireworks AI, OpenRouter

Your choice

Your choice is an instruction to us. We route your requests to the provider you picked, and that provider's own terms and location govern what happens to the data once it arrives. We do not hold a commercial relationship with it on your behalf.

Where they are

Every provider you can select is based in the USA and is also one of the AI providers in section 06, with the transfer basis listed there. The request still leaves through our servers, so a transfer to the USA takes place.

Knowledge-base search

When your assistant searches your knowledge base, the visitor’s message is also sent to OpenAI, through our own OpenAI account and not through your key, to find the matching passages. This happens on every plan, with or without your own key. OpenAI is listed in section 06.

Lanus Agent, at lanus.serlion.com, lets you ask questions about what visitors are saying on your own site.

How data gets there

Conversations are copied to Lanus Agent only for an account whose owner has signed in to Lanus Agent and accepted its Privacy Policy and Data Processing Agreement. For every other account nothing is copied. For a connected account, once a conversation has been quiet for ten minutes it is treated as finished and its transcript is copied to Lanus Agent by a background job; if the visitor comes back, the copy is replaced.

Stopping it

If you never sign in to Lanus Agent, nothing is copied. If you have signed in and want it to stop, delete your Lanus Agent account under Data & Settings in Lanus Agent; we then stop copying your conversations, and the copies Lanus Agent holds are deleted with the account.

Who runs it

Lanus Agent is run by the same business, not by a separate company and not by a third party we disclose data to. For the conversations copied there, we process the copy for you under the Data Processing Agreement, as we do everywhere else. For your own account details we are the controller there too.

Where and how

It follows the same retention windows as in section 05 and uses Anthropic's Claude for its analysis, with Google's Gemini as a backup when Claude cannot answer. Both are listed in section 06.

These are off by default. Each sends data somewhere you nominate, and once it arrives there you are the controller for it.

• Traffic between your browser, the chat widget or the API and our servers is carried over TLS. The one exception is a web page you ask us to import into your knowledge base from an address that starts with http://, which is fetched exactly as you entered it.
• Passwords are hashed with bcrypt and are not recoverable, only checkable.
• BYOK provider keys, and the access details of the shop, Cal.com, Stripe and Slack connections of Serlion Agent, are stored encrypted (AES-256-GCM).
• Outbound requests to customer-supplied URLs are filtered to block server-side request forgery against internal addresses.
• Access to production systems is restricted and authenticated.

Consent

Where processing rests on consent you may withdraw it at any time, with effect for the future.

How to exercise

To exercise any of these, write to legal@serlion.com. We answer within one month, as Art. 12(3) requires.

Complaints

You also have the right to complain to a supervisory authority. Ours is Der Hessische Beauftragte für Datenschutz und Informationsfreiheit. You may also complain to the authority where you live or work.

What we set

On this website and in your dashboard we set only what is strictly necessary to run the service. When you sign in we set two cookies for serlion.com and its subdomains: a sign-in session cookie and a small marker that tells Lanus Agent (lanus.serlion.com) that you are signed in. They last until you sign out or after 30 days without use. Your browser’s local storage holds your sign-in token and account number, and interface preferences such as theme, language and where you were last.

The chat widget on your website

The chat widget stores a few items in the browser of each visitor on the website where it is installed. It uses local and session storage, not cookies: a conversation identifier so the chat can continue (kept for up to 15 days), the visitor’s sound preference, a copy of the widget’s appearance (kept for up to 30 days), small flags such as whether a conversation was rated or a pop-up was already shown, and ticked checklist steps. It sets no advertising or tracking identifiers. The customer who installs the widget controls its website and is responsible for informing its visitors about this storage and for any consent its own website needs. On serlion.com, Serlion is that customer.

The Serlion Agent widget

Serlion Agent stores two items in the browser of each customer on the website where it is installed. It uses local storage, not cookies: a chat token so the chat can continue (kept for up to four hours after the last message) and a random visitor ID that is used only for the daily fairness limit (kept until the browser’s storage is cleared). It sets no advertising or tracking identifiers. The customer who installs the widget controls its website and is responsible for informing its visitors about this storage and for any consent its own website needs.

Links to social networks

The footer links to our pages on LinkedIn and Facebook. They are plain links: nothing is loaded from those networks until you click one, and we use no plugins, pixels or share buttons. Once you are there, the network’s own privacy notice applies. The networks may give us statistics about visits to our pages on them.

No consent banner

There are no advertising cookies and no cross-site tracking, which is why you are not shown a consent banner. Strictly necessary storage does not require consent under § 25(2) TDDDG.

Age checks

We do not ask anyone's age and have no way to determine it. A chat widget receives whatever a person types, and nothing in it verifies who is typing. Saying that we "do not knowingly collect" data from children would imply a check we do not perform.

Accounts

Subscribing requires acting in the course of a trade, business or profession, so we contract with adults. We do not market the service to children.

Your website's visitors

We are your processor, not the controller, so this is not ours to decide. You choose where the widget runs and who sees it. If your site is aimed at children, or is likely to be used by them, then meeting Art. 8 GDPR is your responsibility as controller. In Germany that means parental consent below the age of 16. We will not have any signal that this applies.

This page is updated whenever our processing changes, including when a provider in section 06 is added or replaced. Changes that materially affect customers are announced by email in advance, and customers may object to a new subprocessor under Art. 28(2) GDPR before it is brought into use.