Privacy Policy

1. Data Controller (GDPR Art. 13)

The controller of personal data is:

LEADGRAM S.R.L.

Jud. Argeș, Sat Chitești, Comuna Bogați, Str. Meridianului nr. 96, România

Contact:

[email protected]

2. Data We Collect

2.1 Website and Forms (apply, demo, contact)

• Company name, phone, email (if provided), role, industry
• Description of the material and the requested platforms (TikTok, Instagram, YouTube Shorts)
• Preferred channel, main blocker, contextual note
• Attribution data: UTM (source, medium, campaign, content, term), referrer — when present
• Consent (checkbox on form)

2.2 Leadgram app (account, material, posts)

• Authentication data: email, name (via Clerk)
• Contact data: company, phone, email
• Video material sent for cutting and publishing
• Post and confirmed-view records
• Credentials required to publish — stored encrypted

Contact status is stored locally in the app. Full sync with HubSpot/Pipedrive will be available soon.

2.3 Site Analytics (Plausible)

We collect aggregated traffic data: visited URLs, referrer, device (no tracking cookies). Plausible does not use cookies for tracking. We do not collect identifiable IPs.

3. Purpose and Legal Basis

• Forms and email: a request to cut and publish — basis: your consent (Art. 6(1)(a) GDPR)
• App: publishing short videos and counting confirmed views — basis: contract performance (Art. 6(1)(b) GDPR)
• Authentication: secure access to account — basis: contract performance
• Analytics: site improvement — basis: legitimate interest (Art. 6(1)(f) GDPR)

4. Recipients and Processors

Data may be processed by the following providers (processors or sub-processors):

OpenClaw runs on our server; data is not sent to OpenClaw. Where a post needs processing, content may be sent to OpenAI.

5. International Transfers

Some data may be transferred outside the EEA (notably USA) to Clerk, OpenAI and Resend. Transfers rely on: (i) Standard Contractual Clauses (SCC) approved by the European Commission; (ii) EU-US Data Privacy Framework where applicable. The providers offer adequate safeguards under GDPR Art. 44–49.

6. Automated Decisions and Profiling

Digital employees (AI bots) process user conversations to generate responses. This constitutes automated processing. We do not perform automated profiling that produces legal effects or significantly affects the person. Business decisions (e.g. payment recovery) remain at the user/client's discretion.

7. Data Retention

• Form data: until consent withdrawal or as needed for the service
• App data: for the duration of the contract and after, per legal obligations
• Logs and backups: limited periods for security and recovery

8. Security

We use appropriate technical and organisational measures: encryption in transit (TLS), encrypted credentials for integrations, restricted access, EU infrastructure where possible.

9. Your Rights (GDPR Art. 15–22)

• Access: you may request a copy of your data
• Rectification: you may correct inaccurate data
• Erasure: you may request deletion (“right to be forgotten”)
• Portability: you may receive data in a structured format
• Objection: you may object to processing in certain circumstances
• Withdraw consent: where basis is consent, you may withdraw at any time
• Complaint: you may lodge a complaint with ANSPDCP (Romanian DPA).

10. Cookies and Similar Technologies

We use Plausible Analytics for aggregated analytics. Plausible does not use tracking cookies; it uses a script that collects aggregated data (e.g. pages visited) without individual identification. We do not use advertising or profiling cookies. Essential cookies (e.g. auth session via Clerk) are necessary for the site to function. On first visit we show a consent banner. You can accept (Plausible analytics) or reject (essential cookies only). Your choice is stored for 12 months.

11. Contact

To exercise your rights or for questions about personal data, contact us at:

[email protected]