Colle
Legal

Colle Privacy Policy

Last updated: October 13, 2026

Draft for the pilot. Company details marked [TO CONFIRM] and the text as a whole must be confirmed and reviewed before launch.

This Privacy Policy explains how Colle collects, uses, stores and protects personal data when you visit our website, sign up for the pilot or use the Colle Service. It is prepared in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Lithuanian law.

Colle is a business service. For the work your organisation hands off through Colle — summaries, facts, files and cases — your organisation decides what is processed and is the controller; Colle processes that content on its behalf under our Data Processing Agreement. For everything else described here (our website, accounts, billing, support), Colle is the controller.

01Who we are

02Our two roles

Colle as controller

We decide how personal data is processed for our website, pilot sign-ups, organisation and user accounts, billing, security and support. This policy describes that processing.

Colle as processor

Content your organisation's people put into Colle ("Customer Data") is processed only on your organisation's instructions, under the Data Processing Agreement (DPA) that forms part of our Terms of Service. If you want to exercise your rights over Customer Data — for example, a handoff that mentions you — please contact the organisation that uses Colle; we help them respond.

03Personal data we collect

CategoryData
Pilot sign-upYour work email address, its company domain and the time you signed up
Account dataName, work email, role, and department or job title (from your company directory or sign-in provider); sign-in identifiers from Google Workspace, Microsoft Entra or the Colle sign-in
Customer Data (as processor)Handoff summaries, facts, files, case titles, comments and the personal data they contain
Usage and security dataAudit log entries (who did what, and when), IP address for rate limiting and security, technical request logs without the content of handoffs
Notification dataBrowser and extension push subscriptions (an endpoint address and keys), so notifications can reach your devices
Billing dataBilling contact, company details, invoices and payment history; card details are handled by our payment provider, not stored by us
Communication dataSupport requests, feedback and correspondence
Website analyticsOnly if you allow analytics: aggregate visit and click statistics through Plausible, without cookies or personal profiles

04Purposes and legal basis

We process personal data for these purposes, on the legal bases of GDPR Article 6:

PurposeLegal basis
Creating and running accounts, signing inContract (Art. 6(1)(b))
Providing the Service: handoffs, cases, files, notificationsContract (Art. 6(1)(b))
Billing and invoicingContract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c))
Responding to pilot sign-ups and demo requestsLegitimate interest (Art. 6(1)(f))
Security, abuse prevention, rate limiting and the audit logLegitimate interest (Art. 6(1)(f))
Service notices and supportLegitimate interest (Art. 6(1)(f))
Website analyticsConsent (Art. 6(1)(a)), which you can withdraw at any time
Accounting and other legal requirementsLegal obligation (Art. 6(1)(c))

We do not use personal data or Customer Data to train AI models, and we do not sell personal data.

05Recipients and sub-processors

RecipientPurposeLocation
Fly.ioHosting of the application, database and file storageEU (Frankfurt, Germany)
Push services (Google, Apple, Mozilla)Delivering notifications to your browser or phone; the content is encrypted with your device's key and kept for at most one hourMay be outside the EU
Google Workspace or Microsoft EntraSigning in, if your organisation uses themPer your organisation's agreement
Plausible AnalyticsWebsite statistics, only with your consentEU
Payment provider [TO CONFIRM]Processing payments once billing starts[TO CONFIRM]
AuthoritiesOnly when the law or a court order requires it—

AI assistants

Colle works inside AI assistants such as Claude (Anthropic) and ChatGPT (OpenAI). When you ask your assistant to hand off or read work, the assistant provider processes that conversation under your own or your organisation's agreement with that provider. These providers are not Colle's sub-processors, and Colle does not send them data on its own.

06International transfers

Colle stores personal data and Customer Data in the European Union (Frankfurt, Germany). Some providers are based outside the EU/EEA (Fly.io in the United States; push services may route messages globally). Where personal data may be transferred outside the EU/EEA, we rely on safeguards under GDPR Chapter V:

07How long we keep data

DataRetention
Customer DataFor the subscription; deleted within 30 days after it ends, and from backups within the following 14 days
Account dataWhile the account is active; removed when your organisation deactivates you or ends its subscription
Audit logFor the subscription, exportable by administrators; then deleted with Customer Data
Pilot sign-ups12 months, or earlier if you ask us; deleted automatically after that
Security and request logs30 days
Billing and accounting recordsAs long as Lithuanian accounting law requires (currently 10 years)
Support correspondence2 years after the request is closed

08Your rights

Under the GDPR you have the right to:

To exercise these rights, email hello@trycolle.com. We answer within one month. For Customer Data, contact your organisation first; we help it respond, including erasure, which in Colle destroys the encryption key of a person's personal data in facts.

09Right to lodge a complaint

You may lodge a complaint with a supervisory authority, in particular in the EU country where you live, work or where the alleged infringement took place. In Lithuania:

10Is providing data required?

Providing personal data is voluntary, but some of it is needed to use the Service: a work email address to sign up for the pilot or to have an account, and billing details for a paid subscription. Website analytics are always optional.

11Automated decisions

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. The Service automatically flags text that looks like instructions to an AI assistant and applies rate limits; these protect users and do not decide anything about you. You can contact us if you think a flag or limit is wrong.

12Cookies

Our website stores only your cookie choice and loads analytics only with your consent. The Colle app uses two strictly necessary cookies for signing in. Details and settings are in our Cookie Policy (/cookies/).

13Security

We protect personal data with technical and organisational measures, including:

If a personal data breach is likely to result in a risk to your rights and freedoms, we notify the supervisory authority within 72 hours and, where the risk is high, the people affected (GDPR Articles 33 and 34). For Customer Data, we notify the organisation without undue delay.

14Children

Colle is a service for businesses and is not directed to anyone under 18. We do not knowingly collect their personal data; if you believe we have, contact hello@trycolle.com and we will delete it.

15Changes to this policy

We may update this policy. We announce material changes at least 30 days in advance, by email to administrators and in the Service. The date at the top shows the latest version.

16Contact

This Privacy Policy is prepared in accordance with the GDPR and applicable EU and Lithuanian law. Questions: hello@trycolle.com.

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