Who this covers
Visitors to https://handoru.ai and the waitlist at https://handoru.ai/join-pilot, and businesses that use HANDORU (the product).
Legal / Privacy
Your information stays yours.
This Privacy Notice explains what HANDORU collects through its website, waitlist, accounts, and connected channels, why we use it, and the choices available to you.
The HANDORU chat is generated by an AI agent acting as the business.
This page is not legal advice. We may update it; the effective date is the current version.
Effective date 28 August 2026
Controller
Dušan Zábrodský, OSVČ (fyzická osoba podnikající dle živnostenského zákona), IČO 71958061, DIČ CZ7812062577, Ciolkovského 845/16, Ruzyně, 161 00 Praha 6, Czechia. Contact dusan@handoru.ai. Operating HANDORU.
Two roles
Owner account, waitlist, and website: we are the controller.
Customers’ chat content, booking intent, and calendar events processed for the business: the business is the controller; we are the processor and process that data only to run the agent for them.
What HANDORU is
HANDORU is a WhatsApp-first AI receptionist for small and medium businesses. It answers customers in the channels you connect, uses the business knowledge you add, checks Google Calendar, and does not book until the customer confirms (confirm-before-book, every plan).
Shipped channels: WhatsApp, website chat, and Instagram Direct (Studio and Business). Messenger is not sold yet. We do not sell HANDORU-provisioned phone numbers, marketing message templates, or custom live MCP connectors.
This notice does not make HANDORU a clinic, practice, or healthcare product. Customer copy is for SMBs.
Owner account
Name, work email, business name, role, login credentials (hashed / auth session). Business knowledge you add. Channel connections (WhatsApp, website chat, Instagram Direct on Studio/Business). Google Calendar when connected. Plan choice: Solo (€49), Studio (€99), or Business (€249). Plan checkout uses Stripe when billing is enabled; Stripe handles payment details, and we do not store full card numbers. Support mail to dusan@handoru.ai. Waitlist submissions (name, email, phone if given, role, company, website, industry, country/timezone, team size, conversation volume, channels, workflow notes, systems, timing, consent) via /join-pilot.
We do not ask waitlist or signup forms for patient records, card numbers, or passwords to other tools beyond official OAuth / provider connect flows.
Customer data
Messages and agent replies; channel identity details; booking intent (requested times, confirmations, cancellations, calendar write only after confirm); human-handoff context. We do not use this to advertise to the business’s customers.
Technical data
IP, device/browser, timestamps, error logs, security events on Cloudflare. Essential browser storage (session, locale, theme) — see /cookies. Optional analytics (public website, consent-gated): PostHog (EU cloud). No Google Analytics. No marketing cookies.
Public marketing site may be served from Railway; waitlist mail through Resend; product hosting Cloudflare (Workers / D1).
Purposes and legal bases
Create/run account, operate agent, confirm-before-book, connect channels and Google Calendar: Contract Art. 6(1)(b).
Waitlist/early-access: Consent and/or pre-contract steps.
Security, abuse prevention, diagnosing faults, limited product improvement: Legitimate interests Art. 6(1)(f); right to object.
Optional PostHog: Consent Art. 6(1)(a) / ePrivacy. Off until allowed.
Invoices/tax when a paying customer exists: Legal obligation Art. 6(1)(c).
We do not currently run marketing campaigns from this product. We do not sell personal data. We do not train foundation models on customer chats.
Who we share it with
Cloudflare (Workers/D1) product hosting. Zoho Mail for dusan@handoru.ai. Meta WhatsApp Cloud API when WhatsApp connected. Meta Instagram for Instagram Direct (Studio/Business, if connected). Google Calendar when connected. PostHog eu.i.posthog.com after analytics consent. Railway if still hosting the marketing site. Resend if still sending waitlist mail.
Channel providers process under their policies. Disclose if law requires, to protect from serious harm, or genuine sale of the business.
Where data lives
Product on Cloudflare. Email Zoho. Meta and Google may process in the US and other countries. Transfers outside EEA/UK via provider SCCs plus extra measures where they offer them.
Retention
Waitlist: while early access runs, ordinarily 24 months after last contact.
Owner account and business knowledge: life of the account.
Chat/booking records we hold for you: life of the account unless you delete a thread.
After account close: delete or irreversibly anonymise within 30 days; backups within 90 days except where law requires a longer hold.
Optional PostHog: until consent withdrawn / PostHog settings.
Invoices if any: statutory tax period in Czechia, once a payment relationship exists.
Cookies
See the Cookie notice.
Security
Cloudflare, HTTPS, access limited. We do not claim audits or certifications that have not been verified.
GDPR rights
Access, correct, delete, restrict/object, portability, withdraw consent. Email dusan@handoru.ai (DSAR), verify identity, aim one month. Customer-as-processor requests passed to the business. Complaints: ÚOOÚ https://www.uoou.cz (Czech seat, Praha 6); Garante https://www.garanteprivacy.it (Italy); or the user’s EU authority. No separate DPO currently.
Children
HANDORU is not for anyone under 16.
Business responsibilities
Lawful basis to message; no special-category data they are not set up to handle; AI-generated replies; confirm-before-book and human handoff. Not a substitute for professional, medical, or legal advice to customers.
Changes
Posted on this page with a new effective date; we email the owner or seek fresh consent where required.
Contact
Dušan Zábrodský, OSVČ (fyzická osoba podnikající dle živnostenského zákona), IČO 71958061, DIČ CZ7812062577, Ciolkovského 845/16, Ruzyně, 161 00 Praha 6, Czechia. Contact dusan@handoru.ai. Operating HANDORU. https://handoru.ai, https://handoru.ai/join-pilot.