Privacy Policy

The short version

• Thoth AZ Solutions S.R.L. (Galați, Romania) is responsible for this website and for your SENA account. Your organisation is responsible for what it puts into its SENA workspace; we process that only on its instructions.
• Your documents, records, mail, chats and AI processing stay on servers in the European Union. Sign-in identity goes to Clerk (United States) and payments to Stripe, both under the EU-US Data Privacy Framework. Email we send you goes through Google Workspace.
• We do not sell personal data, do not advertise, and do not train AI models on your data.
• You can object to processing based on our legitimate interests at any time (see the box before section 6), export your data, and delete your account in Settings → Privacy.
• Questions and requests: privacy@sena.systems.

1. Who we are

The controller for the processing described in sections 3 to 8 is Thoth AZ Solutions S.R.L., registered office Str. Piața Falezei nr. 6, demisol, camera 2, 800077 Galați, Romania, Trade Register no. J17/936/2022, CUI 46249620 ("SENA", "we"). Privacy contact: privacy@sena.systems; postal requests: the registered office address above. We have assessed that a data protection officer is not currently mandatory (GDPR art. 37); we will appoint one when 50 organisations have connected mailboxes, or if we ever process national identification numbers on the basis of legitimate interest, and will announce it here.

2. Two roles: when we are the controller and when we are your organisation's processor

A. We are the controller for: visitors to our websites; people who contact us or receive our communications; the people who sign up and use SENA, for the purposes we decide ourselves (securing the login, preventing abuse, metering and billing, and our communications to you); and our customers' contracting, admin and billing contacts. Sections 3 to 8 cover this.

B. We are a processor for everything a customer organisation puts into or connects to its SENA workspace, including its user directory (your workspace profile, role and invitations), the audit log of what you did in its workspace, documents, CRM contacts, employees, invoices, mailboxes, calendars, chat content, and the AI outputs derived from it ("Customer Data"). The customer is the controller and decides why and how it is processed. We process it only on the customer's instructions under our Data Processing Agreement (sena.systems/dpa). If you are an employee, customer, supplier or correspondent of a SENA customer and want to exercise your rights over Customer Data, contact that customer; we will help them respond, and section 9 explains what we do with Customer Data.

3. What we collect as controller, why, and on what legal basis

Our legitimate interests, where we rely on them, are: (1) keeping our websites and the Service secure and detecting abuse; (2) operating and improving our websites and the Service through aggregate counts, diagnostics and error reports; (3) answering and recording business enquiries, support requests and invoicing the organisation you represent; (4) accountability for actions taken in the Service; (5) informing existing customers about similar services; (6) establishing, exercising or defending legal claims. We have documented a balancing test for each; ask for a summary at privacy@sena.systems.

Every marketing message is identified as such, names Thoth AZ Solutions S.R.L. and has a working unsubscribe link; opting out is free and immediate and puts your address on a suppression list. Open and click tracking is switched on only if your consent covers it.

We do not sell personal data. We do not use personal data for advertising. We do not profile users for marketing. Website and product analytics run only if you opt in; they record a user number rather than your name, and they are never used for advertising. Without that, only aggregate counts with no identifier are kept (the "Aggregate traffic and usage counts" row above).

3A. Data we receive from others

Some data does not come from you: (1) if an organisation admin invites you, we receive your name, email, role and language from them; (2) if you are your organisation's billing contact, we receive your name, email and role from the admin and your payment status from Stripe; (3) when an organisation signs up we check its registration data in the ANAF public registry and in Targetare, a commercial company-data service, which can return the names and roles of its legal representatives. We give you this policy in the first message we send you (invitation email, first invoice, first message) and in any case within one month of receiving your data.

3B. What you must provide

To create an account we need a name, a work email and a password or identity-provider login; without them we cannot give you access. Billing contact, company details and VAT ID are required by tax law to issue invoices. A profile picture, language preference and marketing consent are optional. If we intend to use your data for a purpose not described here, we will tell you first and, where needed, ask for your consent.

4. Who receives personal data (recipients and sub-processors)

We use service providers who process data on our behalf under contracts that meet GDPR art. 28. The full, current list with locations and safeguards is at sena.systems/subprocessors. In summary:

• OVHcloud (OVH SAS, France): hosting of all application infrastructure, databases, file storage and backups. Primary systems in Gravelines, France; encrypted backup copies in Germany. EU only.
• TensorX Ltd (Ireland): AI language-model inference, document OCR (scanned pages are sent as images) and text embeddings on GPUs in the EU (Ireland and Finland), with zero data retention and no training on inputs.
• Google Cloud EMEA Ltd (Google Workspace) (Ireland): delivery of the account, notification and digest emails we send you; digest emails can contain summaries derived from Customer Data.
• DataImpulse (Softoria LLC, United States): network egress for web-research page fetches; its relays see the addresses of pages we fetch and the search terms, never your identity or your content.
• Clerk, Inc. (United States): user authentication and identity (name, email, login identifiers, session data). Certified under the EU-US Data Privacy Framework; Standard Contractual Clauses as fallback.
• Stripe (Stripe Payments Europe Ltd, Ireland, with Stripe, LLC, United States): payments, invoicing, and card storage. Stripe is an independent controller for the personal data it processes to provide its payment services, including fraud prevention, regulatory compliance and its own product improvement (stripe.com/privacy).
• Public search engines queried by our own search server for research features (currently Bing, DuckDuckGo, Qwant, Mojeek, Brave, Startpage and Google News): they receive the search terms and our server address, never your identity, account or content.
• Public registries and data sources we query on a customer's instruction for company research (ANAF, ONRC, mfinante, VIES, Targetare, Companies House, OffeneRegister, KVK, BODACC, annuaire-entreprises, TED, TenderNed, GLEIF, GDELT, SEC EDGAR, Google News RSS): they receive the query, never your identity.
• Your organisation's admins see your name, email, role, login history and the audit log of your actions in their workspace.
• ANAF receives our own invoices to Romanian customers through e-Factura, which name the billing contact.
• Professional advisers (accountants, lawyers, auditors) under confidentiality; authorities where the law requires; and, if we sell or merge the business, the successor, who receives your data under this policy after we tell you.

Secrets management, error tracking, caching, the search index, AI trace storage and website and product analytics are self-hosted inside our OVH environment and are not third-party recipients.

Systems you connect (Google, Microsoft, IMAP mail servers, ANAF e-Factura, Linear, Snowflake, Personio, Meta WhatsApp Business) are your own providers under your own agreements with them; SENA receives data from them and writes back only where the connector supports it and you approve it.

5. International transfers

Customer Data, including AI processing and backups, stays in the European Union. Exceptions: sign-in identity data is processed by Clerk in the United States; payment data by Stripe in Ireland and the United States; email we send you is delivered through Google Workspace, which may process it outside the EU; research page fetches pass through DataImpulse relays that may be outside the EU (search terms and page addresses only); and, when the Apps ship, push notification tokens and titles go to Apple and Google in the United States. For United States recipients we rely on the EU-US Data Privacy Framework where the recipient is certified and, as a fallback that applies automatically if the Framework ceases to apply, the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914) with transfer impact assessments. A copy of the clauses and a summary of our transfer impact assessments are available on request at privacy@sena.systems.

Your right to object. Where we process your personal data on the basis of our legitimate interests (security, product improvement, business communications), you can object at any time on grounds relating to your particular situation, and we will stop unless we can show compelling legitimate grounds that override your interests. Where we process your data for direct marketing, you can object at any time, without giving reasons, and we will stop immediately. To object, write to privacy@sena.systems or use the unsubscribe link in any message.

6. Your rights

Under GDPR art. 15 to 22 you can ask us to: access your data; correct it; delete it; restrict processing; receive it in a portable, machine-readable format; object (see the box above); and withdraw consent where consent is the basis, without affecting earlier processing.

In the product you can do most of this yourself: Settings → Account (correct), Settings → Privacy (export your data, delete your account). Deleting your account: deletion is scheduled immediately, your access ends, and the account and its personal data are permanently deleted after a 30-day grace period during which you can ask us to restore it. Deleting your user account does not delete the business records your organisation holds; its administrator controls those. If you cannot sign in, email privacy@sena.systems from the account's address or use sena.systems/delete-account.

For anything else, write to privacy@sena.systems. We answer within one month (extendable by two months for complex requests, with notice and reasons). We may ask you to confirm your identity, normally by replying from the registered email or a login challenge; we do not ask for identity-card copies by default. If we refuse a request we tell you why and remind you of your right to complain.

You may complain to the Romanian supervisory authority: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 Bucharest, dataprotection.ro, or to the authority of the EU country where you live or work, and to the courts.

7. Automated decision-making

We do not make decisions about you based solely on automated processing which produce legal or similarly significant effects (GDPR art. 22). SENA's AI features produce suggestions, analyses and drafts that a human reviews before anything is done with them. See sena.systems/ai for how AI is used.

8. Cookies and local storage

Our website and the application use strictly necessary first-party cookies and local storage to work, keep you signed in and remember your preferences. Analytics cookies are set only if you say yes, separately on the website and in the application. Neither loads third-party analytics, advertising or tracking scripts. Details, including every cookie's name and lifetime, are in the Cookie Policy at sena.systems/cookies.

9. Customer Data: what happens to data inside a workspace

The binding terms are in the Data Processing Agreement; this section explains them.

What is processed. Whatever the customer uploads, enters or connects: documents and files; CRM contacts and companies; sales, invoices, suppliers, inventory; employees, attendance, absences, payroll data; projects and tasks; calendar events and mailbox contents of users who connect their own accounts; chat messages with the assistant; and the briefings, research, drafts and analyses SENA generates from all of it.

How AI processes it. Text, and for scanned documents the page images, is sent to our EU inference provider to generate answers, briefings, summaries, classifications and drafts. The provider processes it in memory and does not store, log or train on it. Documents are converted to searchable embeddings by the same EU provider so the assistant can cite the exact page. Scheduled "beats" run over the customer's data to produce briefings. We do not extract or index sensitive data (health, union membership, political or religious views) from content, and research briefs do not report such data about people. Nothing is used to train models. For debugging, SENA keeps prompt and response traces for up to 30 days in its own infrastructure; only named engineers can read them.

Mail and calendar. When a user connects a mailbox or calendar, SENA keeps a private, read-only mirror for that user. Message bodies and event details are visible only to that user and are deleted when the user disconnects the account or is removed. The organisation's CRM sees limited metadata (who, when, subject, which contact), kept for 30 days by default; the employer can only extend this with a documented justification under Law 190/2018 art. 5, and must inform employees and consult their representatives before connecting mailboxes or calendars. SENA does not send mail or change calendars through a mirror.

Web research. Research features fetch publicly available web pages, through our own search server, the public search engines it queries and a network egress provider, to produce cited briefs about companies and topics the customer asks about. Where those pages or public registries contain personal data about individuals (for example company directors), we process it on the customer's instruction; the customer is the controller and is responsible for its legal basis and for informing the people concerned (GDPR art. 14). If you have been named in a research brief and want it corrected or removed, write to privacy@sena.systems; we will identify the customer and forward your request the same business day.

Who at SENA can see Customer Data. Access to production systems is restricted to named engineers, logged, and used only for support at the customer's request, for security incidents, for failures affecting that workspace, or for legal obligations. Tenant isolation is enforced at the database level. Nobody at SENA reads mirrored mailboxes or calendars except at the written request of the connecting user or of the customer for a security investigation.

Retention and deletion. Customer Data is kept while the workspace exists, subject to the shorter windows above and to per-feature limits (activity digests and workflow runs 90 days, AI traces 30 days). When a workspace is closed its data is frozen, kept 30 days for restoration on request, then permanently deleted; backups age out within 30 days after that. The audit log is kept 13 months. Customers can export their data at any time and for 30 days after closure (self-service bundle, and a complete export on request). Customers' e-invoices are the customer's to archive; they are included in the complete export on request and deleted with the workspace unless the customer orders an archive.

9A. Data from Google and Microsoft APIs

This section is binding on us.

Google. SENA's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

What we access. With your permission SENA reads and, for Drive, writes files in your Google Drive (scope drive), reads your Gmail messages (scope gmail.readonly, available only to organisations approved for the mail mirror) and reads your Google Calendar events (calendar.readonly, calendar.events.readonly). SENA indexes the folders you select in Settings → Integrations (by default a folder named "Sena") and writes generated documents only into that folder; it does not read folders you did not select and never deletes your files. We ask for the drive scope because Google's API cannot otherwise see files that you or your colleagues add later to a folder you created yourself.

How we use it. Only to provide the features you turned on: indexing your documents so the assistant can answer with citations, showing your own mail and calendar in your private mirror, linking messages to CRM contacts by metadata, and producing your briefings. We do not use Google user data for advertising, we do not sell it, we do not use it to develop, improve or train generalised AI or machine-learning models, and we do not use it to improve any other part of the Service.

Who else sees it. Google user data is stored on OVHcloud in France. Text extracted from it is sent to TensorX Ltd (Ireland) to generate your answers, summaries and briefings, under a contract that forbids storing, logging or training on it. Notification titles and digest emails containing summaries pass through the push and email providers listed at sena.systems/subprocessors. Other users in your organisation see only the metadata described in section 9; bodies and file contents you did not share stay visible to you only. We transfer Google user data to no one else except when required by law, for security investigations, or, with notice to you, in a merger or acquisition.

Human access. Nobody at SENA reads your Google user data unless you have given affirmative agreement to us viewing specific files or messages (for example in a support ticket), or reading is necessary for security or abuse investigation, or the law requires it.

How long we keep it. Mail bodies: while the mailbox stays connected. Drive file copies, extracted text and search embeddings: while the file is in the indexed scope and the connection exists. When you disconnect Google, revoke access at myaccount.google.com/permissions, or delete your account, we delete copies, extracted text, embeddings and tokens within 30 days, and from backups within 30 days after that.

How it is protected. See section 11. Refresh tokens are stored encrypted at field level with keys held in our secrets manager. Our security posture for Google restricted scopes is assessed annually under Google's CASA programme.

Microsoft. With your consent, or your Microsoft 365 administrator's, SENA reads files you can access in OneDrive and creates a folder named "Sena" there, which it moves to your recycle bin when you disconnect (Files.ReadWrite; SENA does not change your other files), reads your mailbox (Mail.Read), reads your calendars (Calendars.Read), reads your profile (User.Read) and keeps a refresh token so the mirror stays current when you are not signed in (offline_access). We use Microsoft data only for the features you enabled, exactly as described for Google data above, with the same storage, transfer, human-access, retention and deletion rules, in compliance with the Microsoft APIs Terms of Use. You or your administrator can revoke SENA at myapps.microsoft.com or in the Microsoft Entra admin centre; your organisation may require an administrator to grant consent for all users.

Meta WhatsApp Business (Meta Platforms Ireland Ltd) is the customer's own provider under the customer's agreements with Meta; messages your customers send to your number are stored in your workspace as Customer Data and are never used to train models.

10. Children

SENA is for business use and is not directed at anyone under 18. We do not knowingly collect children's data.

11. Security

We use encryption in transit (TLS 1.2+) and at rest, field-level encryption of connection credentials, tenant isolation at the database level, role-based access, immutable audit logging, daily encrypted backups inside the EU, periodic security reviews, and an information security management system aligned with ISO/IEC 27001 (certification by TÜV Austria Romania in progress, not yet obtained). If a personal data breach affects you we will inform you without undue delay where the law requires it, and we notify ANSPDCP within 72 hours where required. Report security concerns to security@sena.systems.

12. Changes

We will post changes here with a new version and date, and notify account holders of material changes by email or in-app at least 30 days before they take effect where they affect you as a user. Previous versions: sena.systems/privacy/history.

13. Contact

Privacy and data-subject requests: privacy@sena.systems · Security incidents: security@sena.systems · Legal: legal@sena.systems · Thoth AZ Solutions S.R.L., Str. Piața Falezei nr. 6, demisol, camera 2, 800077 Galați, Romania.