Privacy Policy

Last updated: February 21, 2026

1. Introduction

Butlr ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and protect information when you use our Service. By using Butlr, you consent to the data practices described in this policy.

2. Data Controller

The data controller responsible for your personal data is:
Lenny David Enderle
Rua Padre Manuel Bernardes 16, 5 Esq.
Costa da Caparica 2825-359
Portugal

Email: privacy@butlr.cloud

3. Data We Collect

3.1 Account Information

  • Email address
  • Name (as provided during setup)
  • Payment information (processed and stored by Stripe — we do not store card details)
  • Telegram user ID and chat ID (when connecting your bot)

3.2 Service Data

  • AI assistant configuration and preferences (bot name, personality settings)
  • Usage statistics (message counts, feature usage)
  • Technical logs for troubleshooting (server logs, error reports)
  • Installed skills and integration preferences

3.3 Conversation Data

Important: Your AI assistant runs on a dedicated virtual machine assigned exclusively to your account. Conversation context, memory files, and session data are stored locally on your VM to enable continuity and personalization. We do not centrally collect, read, or analyze your conversation content. When your subscription ends, your VM and all data on it are permanently deleted within 30 days.

3.4 API Keys and Credentials (BYOK Users)

If you provide your own API key, it is stored on your dedicated VM instance in an access-restricted configuration file. Your API key is used exclusively to authenticate requests to your chosen AI provider. We do not have access to, log, or transmit your decrypted API key outside your VM.

3.5 OAuth Tokens

If you connect your AI provider account via OAuth (e.g. OpenAI), the resulting access and refresh tokens are stored exclusively on your dedicated VM. We do not store OAuth tokens on our central infrastructure.

4. Legal Basis for Processing (GDPR Art. 6)

We process your data based on the following legal grounds:

  • Contract performance (Art. 6(1)(b)): Processing necessary to provide the Service you subscribed to
  • Legitimate interest (Art. 6(1)(f)): Fraud prevention, security monitoring, service improvement
  • Legal obligation (Art. 6(1)(c)): Tax records, compliance with legal requests
  • Consent (Art. 6(1)(a)): Optional marketing communications (if applicable)

5. How We Use Your Data

  • To provide, maintain, and improve the Service
  • To process payments and manage subscriptions
  • To provision and manage your dedicated VM
  • To send service-related communications (e.g. status updates, security notices)
  • To detect and prevent fraud or abuse
  • To provide customer support
  • To comply with legal obligations

6. Data Sharing

We share data with the following third parties, solely as necessary to provide the Service:

  • Stripe (USA): Payment processing — subject to Stripe's Privacy Policy
  • Hetzner (Germany): Server hosting infrastructure — data stays in the EU
  • Telegram: Bot messaging functionality
  • Your chosen AI provider: AI model requests are sent from your VM directly to the provider you selected (e.g. Anthropic, OpenAI, Google). We are not a party to these requests.

We do not sell your personal data. We may disclose data if required by law, court order, or to protect our rights and safety.

7. International Data Transfers

Your data is primarily stored on servers located in the European Union (Germany). Payment data processed by Stripe may be transferred to the USA under Stripe's Data Processing Agreement and EU Standard Contractual Clauses. We do not otherwise transfer your personal data outside the EU/EEA.

8. Data Storage and Security

We implement appropriate technical and organizational measures to protect your data, including:

  • Encryption of data in transit (TLS/SSL)
  • Access-restricted configuration files for sensitive data (API keys, tokens)
  • SSH key-based access controls for VM management
  • Firewall protection and regular security updates
  • Isolated server instances per customer (no shared environments)
  • Automatic data deletion upon subscription cancellation

9. Data Retention

We retain your account data for as long as your account is active. Upon account deletion or subscription cancellation, we will delete your personal data and terminate your VM within 30 days, except where retention is required by law (e.g. tax records may be retained for up to 10 years as required by Portuguese and EU tax law). Payment records processed by Stripe are subject to Stripe's own retention policies.

10. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR), you have the following rights:

  • Access (Art. 15): Request a copy of your personal data
  • Rectification (Art. 16): Request correction of inaccurate data
  • Erasure (Art. 17): Request deletion of your data ("right to be forgotten")
  • Restriction (Art. 18): Request limitation of processing
  • Portability (Art. 20): Receive your data in a structured, machine-readable format
  • Objection (Art. 21): Object to processing based on legitimate interest
  • Withdraw consent (Art. 7): Withdraw consent at any time where processing is based on consent

To exercise these rights, contact us at privacy@butlr.cloud. We will respond within 30 days. You also have the right to lodge a complaint with the Portuguese data protection authority (CNPD — www.cnpd.pt) or any other EU supervisory authority.

11. Cookies

We use essential cookies only for authentication and session management. These cookies are strictly necessary for the Service to function and do not require consent under EU ePrivacy regulations. We do not use tracking, analytics, or advertising cookies. No third-party cookies are set by our website.

12. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect data from children. If you believe a child has provided us with personal data, please contact us and we will promptly delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or through the Service at least 14 days before the changes take effect. Your continued use after the effective date constitutes acceptance. Previous versions are available upon request.

14. Contact

For privacy-related questions or to exercise your rights:
Email: privacy@butlr.cloud

Data Controller: Lenny David Enderle
Rua Padre Manuel Bernardes 16, 5 Esq.
Costa da Caparica 2825-359, Portugal