TGLogger — Privacy Policy

Version 2.0 · Effective 29 July 2026

This Privacy Policy explains how Altera AI S.R.L. ("Logger", "we", "us") collects and uses personal data in two distinct contexts: (A) your visit to tglogger.com and your relationship with us as a prospective or paying client, and (B) data processed through the self-hosted TGLogger Platform once deployed on a Client's own infrastructure. These are handled very differently, and we want that difference to be clear upfront.

This Policy forms part of, and should be read together with, our Terms and Conditions.

PART A — THE TGLOGGER WEBSITE AND OUR CLIENT RELATIONSHIP

1. WHO WE ARE

Altera AI S.R.L. operates tglogger.com and licenses the TGLogger software platform to businesses. For data described in this Part A, Logger acts as the data controller.

2. DATA WE COLLECT

2.1 Website visitors: standard technical data such as IP address, browser type, device type, pages visited, and referral source, collected via server logs and analytics/cookies (see Section 6).

2.2 Prospective clients: information you submit through contact forms, chat, or email — such as name, company name, email address, Telegram handle, telephone number, business sector, and the content of your inquiry.

2.3 Paying clients: billing contact details, invoicing information, communications related to setup and support, and account credentials for the Platform's admin panel where applicable.

2.4 We do not collect payment card numbers directly; payments are processed by third-party payment processors who maintain their own privacy and security practices.

3. HOW WE USE THIS DATA

We use the data described above to: respond to inquiries; prepare proposals and quotes; deliver setup, configuration, and maintenance services; issue invoices and process payments; provide product updates and support communications; and improve the website and our sales materials. We do not sell personal data to third parties.

4. LEGAL BASIS (WHERE APPLICABLE, E.G. GDPR)

Where EU/UK/EEA data protection law applies, our legal bases are: performance of a contract (for clients), legitimate interest (responding to inquiries, improving our services, business-to-business marketing), and consent (for optional cookies, where required).

5. RETENTION

We retain client and prospect data for as long as needed to maintain the business relationship, comply with tax/accounting obligations, and resolve any disputes, after which it is deleted or anonymized. Website analytics data is retained per the retention settings of the analytics tool in use.

6. COOKIES

tglogger.com may use essential cookies (for site functionality) and analytics cookies (to understand traffic and usage). Where required by law, non-essential cookies are only set with your consent, which you can manage via your browser settings or any cookie banner presented on the site.

7. SHARING

We may share data with: service providers who support our operations (hosting, email delivery, analytics, payment processing, accounting), each bound by confidentiality and data protection obligations; professional advisors (legal, accounting) as needed; and authorities where required by law.

Where you contact us through Telegram, or submit an inquiry that we receive through Telegram, the content of that inquiry is processed by Telegram under its own terms and privacy policy.

8. INTERNATIONAL TRANSFERS

If data is transferred outside your country of residence, we take reasonable steps (such as standard contractual clauses, where applicable) to ensure it receives an equivalent level of protection.

9. YOUR RIGHTS

Depending on your jurisdiction, you may have the right to access, correct, delete, or export your personal data, object to or restrict certain processing, and withdraw consent where processing is based on consent. To exercise these rights, contact info@tglogger.com. You also have the right to lodge a complaint with the Romanian supervisory authority (ANSPDCP, www.dataprotection.ro) or with the supervisory authority of your place of residence.

PART B — DATA PROCESSED THROUGH THE DEPLOYED TGLOGGER PLATFORM

10. SELF-HOSTED MODEL: LOGGER IS NOT THE DATA CONTROLLER FOR YOUR OPERATIONAL DATA

10.1 TGLogger is a self-hosted platform. Once deployed, it runs on infrastructure controlled by the Client (or, if separately contracted, on infrastructure managed by Logger under a distinct hosting agreement). This includes all data the Platform processes in the course of normal use: Telegram messages, contact and audience data collected via scraping or monitoring, group data, dialog history, and any personal data of the Client's own prospects or customers contained within that data.

10.2 For this operational data, the Client — not Logger — is the data controller. The Client is responsible for ensuring it has a lawful basis to collect, message, and store data relating to the individuals it contacts or monitors through the Platform (including compliance with GDPR, CCPA, or other applicable data protection and electronic communications laws in the jurisdictions of the individuals concerned).

10.3 In the standard self-hosted model, Logger has no access to this operational data and does not process it on the Client's behalf.

11. MANAGED SETUP AND SUPPORT ACCESS

11.1 Where the Client engages Logger for managed setup, prompt configuration, or troubleshooting, Logger personnel may incidentally access the Client's deployed instance (e.g., via remote access during setup or a support session) and may view limited samples of data for the sole purpose of configuring or debugging the Platform.

11.2 Any such access is limited to what is necessary for the requested service, is not used for any other purpose, is not retained beyond the duration of the engagement unless otherwise agreed, and is governed by confidentiality obligations. Clients requiring a formal Data Processing Agreement for this incidental access should contact us at info@tglogger.com to execute one.

12. AI PROCESSING (ANALYZER / FIRSTMESSAGE / DIALOG)

12.1 The Platform's AI pipeline (Analyzer, FirstMessage, Dialog, and related prompts) processes message content to classify signals and generate responses. This processing occurs within the Client's own deployment. Where the Client configures the Platform to use a third-party LLM API (e.g., an external AI provider), message content is transmitted to that provider under the Client's own account and is subject to that provider's data handling terms — the Client should review those terms independently.

13. SECURITY

Logger designs the Platform with security controls (role-based access control, 2FA, encrypted secrets, audit logging) available for the Client to configure. Because the Platform is self-hosted, overall security of the deployment — server hardening, network security, backups, and access control — is the Client's responsibility.

PART C — GENERAL

14. CHILDREN

The Services are intended for business use and are not directed at individuals under 18. We do not knowingly collect personal data from children.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated version number and effective date, and active clients will be notified where appropriate.

16. CONTACT

For any privacy-related question or request, contact:

Altera AI S.R.L. — Cube Center, Strada Izbiceni 117–119, Ground Floor, 013254 Bucharest, Romania

info@tglogger.com — +40 774 785 581 — Telegram: @logger_ai

17. EXPLICIT ACKNOWLEDGMENT (CONTROLLER/PROCESSOR SPLIT)

17.1 The controller/processor split described in Part B is not established by passive acceptance of this Policy alone. As part of the onboarding acknowledgment flow described in Section 15 of the Terms and Conditions, the Client must individually acknowledge:

☐ I understand that, because TGLogger is self-hosted on my own infrastructure, I — not Logger — am the data controller for all Telegram messages, contacts, and audience data processed through the Platform, and I am responsible for having a lawful basis to collect and use that data under the laws applicable to the individuals I contact.

☐ I understand that if I engage Logger for managed setup or support, Logger personnel may incidentally access my deployed instance solely to perform the requested service, and I consent to this limited access as described in Section 11 of this Privacy Policy.

17.2 This acknowledgment is recorded with the same timestamp, IP address, and identity metadata described in Section 15.3 of the Terms and Conditions, and is retained as evidence that the Client was informed of and accepted its role as data controller before onboarding.