Legal · pilot draft
Privacy Policy
Draft privacy policy for the Bobby CMS pilot. Incomplete, not final and not legal advice.
No personal data is processed in this build
1. Controller
Toros Ricos OÜ is the controller for account, billing and platform records. Registration number, VAT number, registered address and privacy contact address: [not configured].
2. Roles
- Controller for account, membership, billing and audit data of the service itself.
- Processor for the content a customer stores in a workspace, including any personal data contained in that content.
3. Planned categories of data
- Account data: identifier, name, email address, authentication metadata.
- Workspace data: memberships, roles, invitations.
- Content data: collections, pages, versions and blocks supplied by the customer.
- Credential metadata: API and MCP client names, scopes and hashed keys.
- Operational data: audit events, rate-limit counters, error records.
- Billing data: plan state and payment provider references, held by the provider.
- AI usage data: credit ledger entries recording metered operations.
4. API and MCP processing
When an authorized API or MCP client reads or writes content, the request is processed within the workspace boundary and recorded for audit and rate-limiting purposes. AI agents connecting over MCP hold no greater permission than the credential they present.
5. AI processing and credits
The planned service may offer AI-assisted content operations, metered through credits. Where such a feature is used, the relevant content would be sent to the configured AI provider solely to perform the requested operation. No AI provider is connected in the pilot and no content is sent anywhere.
6. External metadata previews (Iframely)
When a customer references an external URL, the planned service sends that URL to a third-party metadata provider (Iframely) to retrieve publicly available metadata such as title, description, provider name and a thumbnail reference. The URL itself is the personal-data-relevant item transmitted; the external page content is not copied or hosted. Temporary verification documents are metadata-only, short-lived, revocable and excluded from search indexing. This integration is not configured or active during the pilot.
7. Legal bases
- Performance of a contract, for providing the service.
- Legitimate interests, for security, abuse prevention and auditing.
- Legal obligation, for accounting and tax records.
8. Retention
Content is retained while the workspace exists. Audit records are retained for a defined security period. Specific retention periods: [not configured].
9. Sub-processors
A published sub-processor list will accompany the final policy. Planned categories include hosting, payment processing (Stripe), AI processing and URL metadata resolution (Iframely). None is active in the pilot.
10. Your rights
Access, rectification, erasure, restriction, portability and objection apply where the Operator is controller. Requests concerning workspace content are directed to the relevant customer as controller. Contact address: [not configured].
11. Security
Planned measures include strict workspace isolation, deny-by-default authorization through one canonical server-side authority, hashed credentials, immutable audit records, SSRF-protected outbound requests, and server-side-only secret custody.
12. Changes
This policy is versioned with an effective date; material changes are published before taking effect.