Privacy Policy

§ 1Who is the controller

The controller of your account data is the service provider named in the block at the top of this page; for personal data matters write to the address in the Email field. For your clients' data you are the controller, and we process it on your behalf under the terms on the page Data Processing.

§ 2What data we collect

• Account data: email address, name, agency name.
• Your clients' data that you enter yourself or that we read from connected accounts.
• Conversations with the agent and a log of actions in the agency.

§ 3Purpose and legal basis

Only to provide the service: show the state of accounts, prepare content, issue invoices. Account and conversation data is needed to perform the contract (Art. 6(1)(b) GDPR); billing data is kept because tax and accounting law requires it (Art. 6(1)(c) GDPR). We do not sell data and do not use it to train models.

§ 4Who we share it with

Only with entities that perform part of the service, and only when needed: the list, with when data reaches each of them, is on the page Subprocessors.

§ 5How long we keep it

For as long as you use the service and for the period required by accounting law. On request we delete earlier everything except what we must keep for billing: data in the database, files and access to connected accounts, which we revoke with the provider. Backups are encrypted and rotated, so deleted data disappears from them within eight weeks at the latest.

§ 6Evidence of acceptance and consents

When you accept the terms of service, the data processing terms and the declaration that you act as a business, and when you confirm the price of a paid action, we record: the person's email address, the document and its version, the SHA-256 hash of its text, the time, the IP address and a description of the browser. We do this in our legitimate interest (Art. 6(1)(f) GDPR): to show who agreed to what and when, and to defend against claims. The record is kept for the term of the agreement and then until claims become time-barred, also after the account is closed.

§ 7Data from Google accounts

When you sign in with Google or connect a Google account on the Integrations screen, TORIN requests only the scopes listed below, each one separately, for the integration you connect. Consent to one integration gives no access to the others.

• Sign in with Google openid (non-sensitive): your Google account identifier. Used only to sign you in to an agency workspace you have been invited to.
• Sign in with Google email (non-sensitive): your account email address and whether Google has verified it. The address must match your invitation; an unverified address is refused.
• Sign in with Google profile (non-sensitive): the name on your account, so your team can see who did what.
• Google Ads https://www.googleapis.com/auth/adwords (sensitive): structure, settings and performance of the ad accounts you have access to (campaigns, budgets, keywords, conversions, recommendations). TORIN uses it for a daily account health check and to answer your questions. A change to an account (for example a budget or a keyword) is made only after you approve that one specific change, and the previous state is saved so the change can be undone.
• Google Analytics 4 https://www.googleapis.com/auth/analytics.readonly (sensitive): read-only access to reports: traffic, traffic sources, conversions and visits from AI assistants to your client's website. TORIN changes nothing in Analytics.
• Google Search Console https://www.googleapis.com/auth/webmasters.readonly (sensitive): read-only: list of properties, clicks, impressions, CTR, queries and pages from Google Search. Used for traffic and ranking reports.
• Google Business Profile https://www.googleapis.com/auth/business.manage (sensitive): information, reviews and performance statistics of the business profiles you manage. A reply to a review or a change to a profile is published only after you separately approve that one reply or change. TORIN never changes the business name.
• Google Calendar https://www.googleapis.com/auth/calendar.events.readonly (sensitive): read-only access to upcoming events, so TORIN can remind you of client meetings and prepare for them. TORIN does not create events or send invitations.
• Google Sheets https://www.googleapis.com/auth/spreadsheets.readonly (sensitive): read-only access to values in a spreadsheet you point TORIN to. TORIN writes nothing to your spreadsheets.
• Google Merchant Center https://www.googleapis.com/auth/content (sensitive): read-only access to your store's products, their status and the issues that stop Google from showing them. Google has one scope for reading and writing Merchant Center data; TORIN writes nothing to Merchant Center, and improved titles and descriptions are given to you as a file you upload yourself.
• Google Drive https://www.googleapis.com/auth/drive.file (non-sensitive): only files TORIN itself creates, never your whole Drive. When you choose “Export” and “Google Doc”, TORIN saves the report as a new document in your Drive and gives you the link. It cannot see or read any other files, and it never shares or sends the document to anyone.
• Gmail (read) https://www.googleapis.com/auth/gmail.readonly (restricted): reading messages in the mailbox. In the current version the connection can be made, but TORIN does not fetch any messages through it.
• Gmail (drafts) https://www.googleapis.com/auth/gmail.compose (restricted): creating reply drafts that you send yourself. TORIN never sends email on your behalf. In the current version it does not create drafts through this connection either.

§ 8How we use data from Google

• Only to provide the features you see in TORIN: account health checks, reports, the agent's answers and changes prepared for your approval.
• We do not sell it and we do not transfer it to data brokers or advertising networks.
• We do not use it for advertising, including personalized or retargeted advertising.
• We do not use it to develop, improve or train generalized artificial intelligence or machine learning models, and we do not transfer it to anyone for that purpose.
• We do not use it to determine creditworthiness or for lending purposes.
• We transfer it only when necessary to provide a feature you request: data you ask the agent about is sent to a language model provider so that the answer can be generated (see the list of subprocessors, in Polish, on the Podwykonawcy page). Otherwise only on your instruction, for the security of the service, or when required by law.
• No human at TORIN reads this data unless you give explicit consent for specific data (for example when reporting a bug), it is necessary for security purposes (for example investigating abuse), it is required by law, or the data is aggregated and anonymized for internal operations.

TORIN's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. See the Google API Services User Data Policy.

§ 9Storage and deletion of Google data

• Access tokens for Google accounts are stored encrypted (AES-256-GCM), separately for each agency. The language model never sees a token: it is inserted only at the moment of the API call.
• Results of reads (account checks, reports, conversations with the agent, change history) are kept in your agency's data for as long as you use the service.
• When you disconnect an integration, its token is deleted immediately and TORIN stops reading that account.
• When an agency account is closed or deletion of a client's data is requested, there is a 30-day period to cancel; after that we delete the data and revoke the tokens with Google. Backups are encrypted and deleted data disappears from them within eight weeks at the latest. We keep only what the law and accountability require: invoices, payments and the activity log.

§ 10How to revoke access to your Google account

• In TORIN: open Integrations (Integracje), choose the connection and click Disconnect (Odłącz). The token is deleted immediately.
• In Google: go to https://myaccount.google.com/permissions, select TORIN and remove access. This revokes the consent on Google's side, even if you no longer have access to TORIN.
• Closing the agency account revokes the tokens with Google automatically.

§ 11Cookies and browser storage

The hiretorin.com website stores no cookies and nothing in browser storage. After you sign in, the app stores a session cookie valid for 30 days and not accessible to page scripts, and after an action a message cookie for 60 seconds. Browser storage keeps only whether the app's sidebar is collapsed. The client portal has its own session cookie of the same kind. The sign-in screen stores a device cookie valid for 365 days that opens nothing and only recognises your browser: a sign-in from a new device is reported to you by email straight away. For each session we keep the browser type and IP address, shown in Settings, Active sessions, to protect the account from takeover (Article 6(1)(f) GDPR). We use no advertising or analytics cookies.

§ 12Your rights

You have the right to access, rectify, erase and port your data, and to object to and restrict processing. Just write to the address in the Email field. You also have the right to lodge a complaint with the Polish supervisory authority (Prezes Urzędu Ochrony Danych Osobowych).

Working draft, before final legal review. It describes what the system actually does and does not replace a contract.