Privacy Policy

For your archived conversations, we are a processor. The data originates in your Intercom workspace, it belongs to you, and we act only on your instructions. You are the controller. We never use it for our own purposes, never analyse it to improve the product, and never train models on it.

For your account, we are a controller. Your email address, company name and billing details are ours to hold because you have a relationship with us.

• Account and identity: your email address, name, company name and role.
• Billing: company name, billing contact, invoices and subscription status. We invoice directly and hold no card details.
• Security and audit: sign-in times, IP address and user agent, and a record of every access to archived data — retained because an audit trail nobody can alter is the product.
• Support: correspondence you send us.

Our lawful basis is performance of our contract with you, and our legitimate interest in keeping the service secure and accountable.

Whatever exists in the Intercom workspace you connect: conversations and their full message content, contacts, companies, tags, help-centre articles, and the teammates and teams involved. That content may contain personal data about your customers, and its nature is determined by you, not by us.

We read it under a read-only OAuth grant. We cannot write to, modify or delete anything in your Intercom workspace.

• Every archived record is encrypted with its own key before it is stored. The keys are wrapped by a workspace key, which is wrapped by a root key held outside the database.
• Records are written to Amazon S3 under Object Lock for the retention period you set, with governance-bypass permission denied across our AWS organisation. Enterprise Compliance mode removes the storage-level override entirely.
• To provide search, Render PostgreSQL in Virginia stores names, email addresses, conversation titles and tags without application-level encryption. Render encrypts the database at the infrastructure level. Archived message bodies are not stored in PostgreSQL.
• Every human view, search, export and download of archived data is written to a hash-chained audit log that rejects edits and deletions at the database level.

Our sub-processors are listed in full, with what each one can and cannot see, at our sub-processor list. We give 30 days’ notice before adding or replacing a sub-processor that processes Customer Personal Data. To be notified, email security@converight.com.

Thinkdata Labs LLP is established in India, which has no EU adequacy decision. Archived content is stored in AWS us-east-1, Northern Virginia, and is accessible to our staff in India for support and operations.

Our Data Processing Addendum is published and incorporated into the Terms, taking effect for each customer when they accept the Terms or otherwise execute the Agreement. It names the transfer mechanism: the EU Standard Contractual Clauses for transfers from the EEA — Module Two where legally available, subject to the Article 3 assessment — and the ICO’s International Data Transfer Addendum for transfers from the UK.

We accept enquiries from EEA and UK customers. We will not begin processing involving a Restricted Transfer until the applicable transfer assessment is complete and the required DPA and transfer terms are executed.

If you are established in the EEA or UK, or your own customers are, raise it during procurement and we will tell you where the assessment stands. Email privacy@converight.com.

You choose the retention period for archived records; the default is 365 days. Records under an active Legal Hold are preserved past that point until the hold is released.

Disconnecting a workspace destroys the stored access token immediately and stops all backups. Your archive is retained for the documented period after cancellation and then crypto-shredded.

How erasure actually works. Because archived objects are under Object Lock, they are not deleted on request. An erasure request instead destroys the encryption key for each affected record. The object remains locked and permanently unreadable. Converight treats this as its technical method for supporting erasure, while the legal treatment of residual ciphertext remains context-dependent.

Where we are the controller of your account data, you may request access, correction, erasure, restriction, portability, or object to processing. Write to privacy@converight.com and we will respond within 30 days.

Where we are a processor, requests about archived content should go to the company whose workspace holds it. If you contact us directly we will pass the request to them and support them in answering it.

Because an archived record cannot be altered or deleted, how each of these rights works against an immutable archive is set out separately, including what each one can and cannot reach.

One limit is worth stating plainly: the audit log is append-only and retains the email address of whoever performed each action indefinitely, because an evidence record that can be edited is not evidence. Where that retention is justified as a security and integrity measure, an erasure request may not remove those entries. We will tell you which entries are affected and why.

You may complain to a supervisory authority. In the EEA or UK that is the authority for your country of residence.

Thinkdata Labs LLP, trading as Converight.
Registered office: #176, First Floor, Sector-10, Panchkula, Haryana 134109, India
LLP registration number: AAI-9081
Privacy: privacy@converight.com · Security: security@converight.com

Whether Article 27 requires us to appoint an EEA/UK representative is under the same legal review. This policy will name one, or record that it is not required, once that is settled.