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Privacy Policy

This English translation is provided for convenience. In case of any discrepancy, the Spanish version prevails.

Last updated: 2026-10-11.

This Privacy Policy describes how ChatMe OÜ (hereinafter "ChatME", "we" or "our") processes the personal data you entrust to us when you use our AI chatbot platform at app.chatme.es or when you interact with a chatbot that one of our customers has embedded on their website.

1. Identity of the data controller
Legal name ChatMe OÜ
Commercial register 17391989 (Estonia)
Tax ID / VAT EE102933761
Registered office Järvevana tee 9, Tallinn, 11314, Estonia
Email for privacy matters privacy@chatme.es
Supervisory authority AKI (Andmekaitse Inspektsioon, Estonia) as lead authority; AEPD for residents of Spain

2. Are you a customer or a visitor?

This policy covers two distinct relationships:

A. If you have a ChatME account (you are a "customer" or "owner") ChatMe OÜ is the data controller for your account data (email, name, billing details, etc.).

B. If you have chatted with a chatbot created by one of our customers (you are a "visitor") Our customer is the data controller for your conversation data. ChatME acts as a data processor on their behalf, under the documented instructions in our Data Processing Agreement (DPA) with the customer.

If you have interacted with a chatbot and want to exercise your rights (access, erasure, portability), you should first contact the customer whose chatbot you used. If you receive no response or do not know who they are, write to us at privacy@chatme.es and we will help you locate them.

3. What data we process and why

3.1 Customers (holders of accounts at app.chatme.es)

Data Purpose Legal basis (GDPR Art. 6) Retention
Email Identification, login, transactional communications Performance of a contract Account lifetime + 30 days
Password (hashed) Authentication Performance of a contract Account lifetime + 30 days
Full name Personalization + customer support Performance of a contract Account lifetime + 30 days
Business name Context in the dashboard + emails Performance of a contract Account lifetime + 30 days
Preferred language Dashboard personalization Performance of a contract Account lifetime
Plan + subscription status Billing + service management Performance of a contract Account lifetime + 30 days
Stripe customer / subscription (ID) Payment processing Performance of a contract Account lifetime
Billing details (address, tax ID) Tax obligations Legal obligation 10 years (tax legislation)
Browser IP address (access logs) Security + abuse prevention Legitimate interest 30 days
Browser signals for the bot check (Cloudflare Turnstile), when the sign-up, sign-in or password-reset screen opens (also if you then sign in with Google): among others, IP address, TLS fingerprint, User-Agent and the page's origin Security: preventing automated sign-ups and sign-ins Legitimate interest ChatME does not store them: it only receives a one-time code, which expires after 5 minutes; when Supabase verifies it, it sends it to Cloudflare. What Cloudflare does with the signals: §5
Delivery record of the emails we send you (email type, the recipient's domain — never the address — and whether it was delivered, bounced or marked as spam) Checking that our emails arrive Legitimate interest 90 days

3.2 Visitors (end users of the widget)

We process the following data on behalf of our customer (the chatbot's owner), not as a controller:

Data Purpose Retention (default, configurable by the customer)
Conversation messages Generating responses using AI 90 days
Form data (name, email, phone, etc.) Enabling the customer to contact you 365 days
Booking/appointment details requested in the chat (name, phone, email, service, preferred time and any notes you write) Handling the appointment so the business can confirm it 365 days, then anonymised: your personal details are erased and the business keeps only the booking record (service, time, status)
Jobber activity record (if the business connected Jobber: name, email, phone, what you asked for and the date of the appointment moved or cancelled) Letting the business check in ChatME what the assistant saved or changed in its Jobber (a backup; Jobber is the source of truth) 365 days, then anonymised: your personal details are erased and only the record remains (type, date, Jobber identifiers)
Let's Book activity record (if the business connected Let's Book: name, email, phone, boat model, dock, pickup and return times, booking reference and its status changes) Letting the business check in ChatME what the assistant booked or changed in its Let's Book (a backup; Let's Book is the source of truth) 365 days, then anonymised: your personal details are erased and only the record remains (boat, dock, times, status, Let's Book identifiers); the free text of a change request is erased too
Restoo activity record (if the business connected Restoo: name, email, phone, table date and time, party size, dining area, booking status, and any special requests or allergies you gave) Letting the business check in ChatME what the assistant booked or changed in its Restoo (a backup; Restoo is the source of truth) 365 days, then anonymised: your personal details are erased (the free text of requests and allergies too) and only the record remains (date, party size, area, status and Restoo identifiers). Failed verification attempts (a code with no email or phone number) are anonymised after 2 days
An order lookup (if the business connected its online store: the order number, email and last name you give, and what the assistant tells you about that order) Checking the order is yours and telling you where it is Not stored separately: it is part of the conversation (90 days). The order's details are read from the business's store at that moment (see §3.7)
Session ID (random) Conversation continuity 90 days (together with the conversation)
Your phone number (only if you write via WhatsApp) Receiving your message and being able to reply in the same thread 90 days (together with the conversation)
Your WhatsApp profile name (if public) Identifying the thread in the business's dashboard 90 days (together with the conversation)
Your Instagram, Messenger or Telegram user ID (only if you write via Instagram DM, the Facebook Page or the Telegram bot) Receiving your message and being able to reply in the same thread 90 days (together with the conversation)
Device type, referrer Basic analytics for the customer 90 days
Clicks on links within the chat Engagement metrics 180 days
IP address (access logs) Security + abuse prevention 30 days

The chatbot may operate on the Customer's website (widget), on their direct-link page, or on the messaging channels the Customer connects (Instagram, WhatsApp, Facebook Messenger and Telegram). On those channels, messages additionally pass through Meta's or Telegram's API (see sub-processors, section 5). Processing is NOT identical to the widget: on the web we identify you with a random session ID, whereas on WhatsApp and Instagram Meta gives us a real, permanent identifier for you — your phone number on WhatsApp (and your profile name, if public) or your user ID on Instagram, Messenger or Telegram (and your profile name) — because without it there is no thread to reply to. These are stored alongside the conversation and deleted with it.

Imported WhatsApp history (optional, the business decides). If the business connects its WhatsApp number while keeping its phone (coexistence), it can request — by explicitly ticking it at connect time and confirming again on its own handset — that Meta transfer to ChatME its WhatsApp conversations from the last 180 days (text only). That history belongs to the business (it is its own WhatsApp inbox) and appears in its panel alongside every other conversation; its assistant uses it as context to serve customers better. We never import the phone's address book, and we never download files or images from the history. Imported conversations follow the same regime as all others: same retention (90 days from import), same right to erasure (§6) and same export.

ChatME never uses this data to train AI models, nor does it share it with third parties beyond the sub-processors listed in section 5.

3.3 Google data you connect (Google Calendar)

If you are a customer and connect your Google Calendar account to your chatbot (an optional appointment-booking feature), we process the following Google data under your explicit authorization and solely so that your chatbot can manage your appointments. You connect and disconnect the calendar yourself from your dashboard.

Google data / scope Purpose How we use it
Availability (busy/free slots) of your primary calendar — calendar.freebusy scope Checking whether the requested time is free before booking, to avoid double bookings We only read busy/free ranges; never the titles, descriptions, attendees or content of your events
Creating events in your primary calendar — calendar.events scope Creating the appointment event when a visitor confirms a date and time in the chat We only create new appointment events; we do not read, modify or delete your existing events

Limited Use (Google API Services User Data Policy). ChatME'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.

3.4 Jobber data you connect (Jobber)

If you are a customer and connect your Jobber account to your chatbot (an optional feature on the Pro and E-commerce plans; connected from your dashboard or from Jobber's App Marketplace), we process the following data under your explicit authorization and solely so that your chatbot can work with your Jobber. You connect and disconnect Jobber yourself.

Data Purpose How we use it
What a visitor types when asking for a quote or a callback (name, email and/or phone, and what they need) Creating the client and the request in your Jobber account, with "ChatME" as the lead source We only create clients and requests; if that email already exists as a client in your Jobber (or the phone, when the visitor gives no email), we reuse that client instead of duplicating it
The email and phone a visitor gives to manage their appointment Verifying they are a client of your Jobber (both must match) and showing them only their own upcoming appointments We read your clients and their appointments solely for that verification and that list
The changes a visitor asks for on their own appointments (move, cancel) Applying the change in your Jobber Only on the verified client's appointments, never on anyone else's

3.5 Let's Book data you connect (Let's Book)

If you are a customer and connect your Let's Book account to your chatbot (an optional feature on the Pro and E-commerce plans; connected by pasting into your dashboard an API key you create yourself in your own Let's Book dashboard), we process the following data under your explicit authorization and solely so that your chatbot can work with your Let's Book. You connect and disconnect Let's Book yourself.

Data Purpose How we use it
What a visitor types when reserving a boat (first and last name, email; phone and preferred language if given — on WhatsApp, the number you write from; party size, dock, boat model, and pickup and return times) Creating the customer and the booking in your Let's Book account, with "chatme" as the partner code We only create customers and bookings; if that email already exists as a customer in your Let's Book, we reuse that customer instead of duplicating it. The booking is held as a draft, and it is Let's Book that emails the visitor its own confirmation with its payment link: ChatME never takes payments or sees payment details
The booking reference and email a visitor gives to manage their booking (on WhatsApp, their number can stand in for the email) Verifying they are a customer of your Let's Book (both must match) and showing them only their own booking (status, times, dock, outstanding balance) We read your customers and their bookings solely for that verification and that lookup
The changes a visitor asks for on their own booking (move, cancel) Leaving a note with the request on the booking, in your Let's Book; or, only if you enable it in ChatME, applying the change or the cancellation Only on the verified customer's booking, never on anyone else's

3.6 Restoo data you connect (Restoo)

If you are a customer and connect your Restoo account to your chatbot (an optional feature on the Pro and E-commerce plans; connected by entering your Restoo account id and the partner API key Restoo issues for your restaurant), we process the following data under your explicit authorization and solely so that your chatbot can work with your Restoo. You connect and disconnect Restoo yourself.

Data Purpose How we use it
What a visitor types when booking a table (name; email and phone number — on WhatsApp, the phone is the number they write from and the email is optional; language; party size, including children if your Restoo distinguishes them; date, time and dining area; special requests, allergies and special occasion if given) Creating the customer and the booking in your Restoo account Restoo itself sends the visitor every communication (confirmation, reminders) and, if your venue requires a card guarantee or prepayment, collects it on its own secure page: ChatME never sees or handles payment data
Outside WhatsApp (web, Instagram, Messenger, Telegram), the phone number the visitor gives, just before creating their booking Checking in your Restoo whether that number already belongs to another customer record, so as not to overwrite it, and whether it already holds a booking in that service that day We check in your Restoo whether that number already belongs to another customer record, so as not to overwrite it: from that record we read, without keeping them, the email and the marketing consent. If the record has a different email or no email (or the number is on more than one record, or it can't be checked at that moment), the booking is created with the visitor's name and email only; if it has the same email, the marketing consent it already had is kept. We also read, without keeping them, that number's bookings for that day: if it already holds one in the same service that isn't cancelled, declined or marked as a no-show (at any time, the same one included), or they can't be read at that moment, the booking is also created without the number, so that the answer never depends on that number's other bookings. Nor does the number go on an early-hours booking asked for after midnight (the restaurant's day began the evening before, and those bookings can no longer be read). We keep the number they gave in our own record even when it isn't sent to Restoo, to verify later that the booking is theirs. We don't store the customer identifier Restoo returns, and we never tell the visitor whether they are on your customer list
On WhatsApp, the number the visitor writes from, when they book Keeping the marketing consent of their record in your Restoo, and checking before creating the booking whether that number already holds a booking in that service or the restaurant doesn't accept their bookings The booking is created with that number, so the record in your Restoo that holds it is updated with the name and language the visitor gives, and with their email if they give one. The marketing consent the record already had is sent back (if the check fails, or several records with that number disagree, it is sent without consent). We don't store the customer identifier Restoo returns, and we never tell the visitor whether they are on your customer list
Outside WhatsApp (web, Instagram, Messenger, Telegram), the email and phone number the booking was made with, and its day and time, which the visitor gives to manage it Verifying the booking is theirs — all four must match the booking — and showing them only that one (date, time, party, status); bookings are never listed We read the bookings in your Restoo for that day and the next under that phone number (for an after-midnight time, the day before's too), the bookings made through the chat with that email and phone number, and, if they give a booking reference, that booking, solely for that check. Bookings made through the chat are compared with our own record of the booking (email and phone number); others with the email and phone number on the customer record in your Restoo; for both, the day and time with the booking's. If the visitor changes or cancels the booking, the email and phone number stay in our record of that action
On WhatsApp, the number the visitor writes from, to manage their bookings Showing them only that number's bookings (date, time, party, status) Bookings made through the chat are compared with the phone number in our own record of the booking; others with the phone number on the customer record in your Restoo. No email is needed
Outside WhatsApp, each verification attempt (also when booking, before checking whether you already have a booking on that same day at that same time): a code computed with a secret key from the email and phone number given (we keep neither the email nor the phone number) and the conversation it came from Limiting attempts — 3 per conversation and 5 with the same email and phone number, in both cases within the last 24 hours — so nobody can guess the day and time of someone else's booking; at the limit, the assistant gives the restaurant's phone number Used only to count attempts, and stored before the search. When looking for a booking, it is normally deleted as soon as the attempt matches a booking, when the limit had already been reached (no search is made then) or when the attempt can't be completed because of a technical failure. When booking, it is deleted only if the booking is made, if the limit had already been reached (nothing is checked or booked then) or if the attempt counter itself can't be read. If the deletion itself fails, it is anonymised after 2 days. In every other case it is anonymised after 2 days, including when the check finds a booking or the booking is not created. The answer to a failed attempt is always the same: it never says which detail didn't match or whether the booking exists
The changes the visitor requests on their own booking (move, resize, cancel) Applying the change or cancellation in your Restoo, where your Restoo configuration allows it Only on the booking verified that way; if cancelling carries a fee under your policy, they are told first and it is only cancelled if they accept

3.7 Online store data you connect (E-commerce plan)

If you are a customer and connect your online store to your chatbot (an optional feature on the E-commerce plan, for stores on Magento 2, Magento 1 / OpenMage, Shopify, WooCommerce or PrestaShop; connected by pasting into your dashboard the API keys you create in your own store), we process the following data on your behalf, under your explicit authorization and solely so that your chatbot can answer with your store's data. You connect and disconnect the store yourself.

Data Purpose How we use it
The order number, email and last name a visitor gives in the chat Verifying the order is theirs before showing them anything We send your store only the order number; the email and last name are compared on our server with those of the order it returns. What your store returns to find it (the full order, which can include the buyer's name, addresses and phone, or several orders with similar numbers) is held only in server memory for that check: it is never shown or stored. If all three details do not match, the chatbot shows nothing about the order
The verified order: status, date, items (name, quantity and price), total and currency, shipping method, carrier, and tracking number and link (the link can carry the destination postcode and country) Answering "where is my order?" Read live and, only after verification, passed to the AI model (Anthropic, USA, under SCCs; see §5) to write the reply. We do not store it separately: only what the assistant writes stays in the conversation (§3.2 retention)
Your catalogue (PrestaShop only, if you turn on live stock): name, reference, link and availability of the products matching what the visitor asks Saying whether a product is in stock right now Business data, not personal data; passed to the AI model to write the reply. We never read prices or give quantities

4. Browser storage (cookies and similar technologies)

When you interact with a chatbot, we store the following in your browser's sessionStorage (these are not cookies and are not sent to the server):

We do not use tracking, analytics or advertising cookies. We do not share information with social networks, Google Analytics, or similar services.

The full details of cookies and browser storage (public website, dashboard and widget) are set out in our Cookie Policy.

5. Who else processes your data (processors and sub-processors)

The full, up-to-date list is available at: /legal/en/subprocessors.

Summary:

The customer's online store is not a sub-processor. If the customer connects their store (E-commerce plan, see §3.7), the platform it runs on — Magento, WooCommerce or PrestaShop on their server or with their hosting provider, or Shopify — is their own system and processes that data for them, under their own contract: ChatME only queries it on their behalf, which is why it is not on this list. A verified order's details do pass through Anthropic (above) to write the reply.

All transfers outside the EEA are governed by Standard Contractual Clauses (SCCs) approved by the European Commission or by a Commission adequacy decision (for Cloudflare, the EU-U.S. Data Privacy Framework).

6. Your rights

You have the right to:

How to exercise them:

You have the right to lodge a complaint with the supervisory authority (AKI in Estonia, AEPD in Spain) if you believe the processing infringes the GDPR.

7. Security

8. Automated decision-making and profiling

ChatME uses AI models to generate responses in the chat. These responses do not constitute "automated decisions with legal or similarly significant effects" under GDPR Art. 22 — they are informational conversations. The chatbot's customer may use the form data to make their own decisions (handling a booking, answering an inquiry), under their own responsibility.

In accordance with the EU AI Act (Regulation (EU) 2024/1689), we always inform you that you are talking to an AI system: an "AI" badge appears in the widget next to the chatbot's name.

9. Changes to this policy

We publish changes at this same URL. If the changes are material (they affect your rights or introduce new sub-processors with access to your data), we will notify you:

10. Contact

For any matter relating to this policy or the processing of your data:

privacy@chatme.es

ChatMe OÜ · Järvevana tee 9, Tallinn, 11314, Estonia