Chiaro – Privacy policy

This policy explains which personal data the questions service of Chiaro (chiaro-api.tceitalia.com) processes, why and for how long, under Regulation (EU) 2016/679 (GDPR).

1. Data controller

TCE Italia di Torresin Michele, via Poste 1, 36055 Nove (VI), Italy, VAT number 02803360243. Contact: info@tceitalia.com.

2. What stays on your site

Store data (orders, products, customers, amounts) never reaches the service: queries run on your site, read-only, through views that exclude customer names, emails and phone numbers.

3. What data we process

Site account: site domain, email address entered at activation, plugin version, creation and verification dates, account status, question balance and automatic top-up settings. The verification code is stored only in hashed form and expires after 15 minutes.
Questions: for each question the plugin sends the text of the question, the structure of the data (names and descriptions of the columns) and, for follow-up questions (“and in June?”), up to 3 previous questions of the same conversation with their query, never the results. The service forwards it to the artificial intelligence model and does not store the text of questions or the answers: in the log we keep only the date, the question identifier, the model used, the number of tokens and the cost.
Purchases: Paddle transaction and customer identifiers, pack, amount and date. Card data is processed only by Paddle: we never see it.
Technical data: IP address and request data, used for security and for the limits against abuse. Technical logs do not contain full email addresses and are kept for 30 days.

The text of a question may contain personal data if you write it (for example “how much did Mario Rossi spend?”). We recommend that you don't: the “Ask Chiaro” buttons use the numeric customer identifier, not the name. For this data the store is the controller and we act as processor (DPA available on request).

4. Why we process it and on what legal basis

Providing the service: activation, answers, balance, top-ups (performance of the contract, art. 6.1.b).
Security, prevention of abuse and of multiple free gifts, cost control (legitimate interest, art. 6.1.f).
Accounting and tax obligations on purchases (legal obligation, art. 6.1.c).
Service emails: verification codes, notices about the balance and automatic top-up, changes to the terms (performance of the contract). We do not send advertising without your consent.

5. Who receives the data

Google (Gemini API, paid service): receives the text of the question and the structure of the data to write the query. With the paid service Google does not use this content to train its models. Processing may take place outside the European Union, under the standard contractual clauses provided by Google.
Paddle.com: handles payments as reseller and processes payment data as an independent controller (paddle.com/legal/privacy).
OVHcloud: provider of the server the service runs on, in the European Union.
Partner agency, only if you enter its code in the plugin: to calculate its commission it may receive from us the site domain and the amounts of the purchases, never the questions or the store data.
Brevo (Sendinblue SAS, France): sends the service emails (codes and notices) and receives the email address and the text of the message for this purpose, in the European Union.

These providers process data on our behalf and according to our instructions, except Paddle for payments. We do not sell personal data to anyone.

6. How long we keep it

Site account: as long as the account is active. If you ask for deletion we delete the email and the account data within 30 days, except what we must keep by law.
Purchase and question log: 10 years, for accounting obligations.
Verification codes: 15 minutes. Limit counters: a few hours. Technical logs: 30 days.

If you uninstall the plugin, the balance stays linked to your account and you get it back by activating Chiaro again with the same email.

7. Your rights

You can ask for access to your data, rectification, erasure, restriction of processing and portability, and object to processing based on legitimate interest, by writing to info@tceitalia.com. We reply within 30 days. You also have the right to lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali (garanteprivacy.it).

8. Security

The service works only over HTTPS. Site keys are encrypted, verification codes are stored as hashes and every request from the plugin is signed. Access to the server is restricted to those who run the service.

9. Changes

If we change this policy in an important way we will tell you by email. The date of the latest version is shown at the top.