Privacy Policy

1. Introduction

ESTEL ("we", "us", "our") is committed to protecting your privacy. This policy reflects our role as a Sales Workflow Orchestrator.

Estel as Data Controller: We are the Controller for your account information, billing, and platform usage data.

Estel as Data Processor: We act as a Processor for any "Buyer Data" (professional contact details) you retrieve from third-party integrations (e.g., Apollo.io). In these instances, you are the Data Controller.

2. Information We Collect

2.1 Information You Provide Directly

User Account Information: Name, email, company, and billing details.

Integration Credentials: We store encrypted OAuth tokens or API keys that you provide to connect Estel to third-party services. These are encrypted at rest using Fernet (AES-128).

Communication Data: Support requests and chat interactions.

2.2 Information We Collect Automatically

Standard usage logs, IP addresses, and device data to ensure security and platform performance.

2.3 Data Processed via Integrations (Lead Data)

Unlike traditional data brokers, Estel does not maintain a global database of leads. We process:

Enrichment Data: Names, professional emails, and phone numbers retrieved from your connected accounts.

Transient Storage: This data is stored only within your private chat history to provide service continuity.

3. Legal Basis for Processing

Contractual Necessity: To provide the orchestration platform you subscribed to.

Legitimate Interest (Estel): For "Blurred Discovery" (previewing job titles without PII) and platform security.

Legitimate Interest (User): You, as the Controller, are responsible for the legal basis used to identify and contact buyers.

4. How We Use Your Information

• Workflow Orchestration: Connecting your search criteria to third-party data results.
• AI Generation: Creating personalized outreach scripts using non-training LLM APIs.
• Matching Logic: Using de-identified metadata (hashed job titles) to improve search relevance.

5. How We Share Your Information

We engage the following sub-processors to facilitate the service:

• Infrastructure: AWS (EU Regions) for hosting.
• Data Enrichment: Apollo.io (via your user credentials).
• AI Content: OpenAI/Anthropic (via API-tier non-training agreements).
• Authentication & Billing: Firebase and Stripe (USA).

6. International Data Transfers

While we prioritize EU/EEA storage (AWS), some sub-processors operate in the USA. We utilize Standard Contractual Clauses (SCCs) and ensure all US-based partners participate in the Data Privacy Framework (DPF) where applicable.

7. Data Retention

8. Your Privacy Rights

Under GDPR, you have the right to access, correct, or delete your data. Because we act as a Processor for your leads, requests to delete specific buyer data should be managed through your Estel "Clear History" settings or directed to the original data source (e.g., Apollo.io).

9. Security and Data Protection

Encryption: We use TLS 1.2+ for data in transit and AES-256 for data at rest.

Credential Safety: Your third-party tokens are never stored in plain text; they are encrypted using a per-user master key.

Isolation: Your processed lead data is logically isolated and never shared with other users.

10. Children's Privacy

Our Services are strictly B2B and not intended for individuals under 18.

11. Contact Information

Info: info@estel.tech

Address: ESTEL, Sofia, Bulgaria

12. Cookies and Tracking

We use essential cookies for authentication and functional cookies (via Matomo/Hotjar) for platform optimization. See our Cookie Policy for details.

13. Changes to This Privacy Policy

We may update this policy to reflect changes in our orchestration features or regulatory requirements. Updates are effective immediately upon posting.