1. Who we are
OpenAlice Laboratories ("OpenAlice", "we") operates the OpenAlice Embed service — an AI brand representative that answers visitors on our customers' websites — together with this website and the customer dashboards. Contact for all privacy matters: nao@openalice.eu. The registered operator details are listed in the Impressum.
2. The two roles we play
We process personal data in two distinct roles, and your rights run against the right party:
- As controller — for data about our own customers and site visitors: account data, billing data, and the operation of this website.
- As processor — for conversations that website visitors have with a Lily widget embedded on a customer's site. There, the customer is the controller and we act strictly on their documented instructions under our Data Processing Agreement. If you spoke with Lily on someone else's website, please direct requests to that website's operator first — we support them in answering you.
3. What we process, and why
- Account data (name, email, company, workspace settings) — to provide the dashboard and support. Legal basis: performance of contract, Art. 6(1)(b) GDPR.
- Billing data — processed by our payment provider Stripe Payments Europe, Limited (Ireland). We never see or store full card numbers. Legal basis: Art. 6(1)(b) and legal obligation, Art. 6(1)(c).
- Widget conversations (messages, optional voice, optional lead details a visitor chooses to leave) — processed on behalf of the customer. Transcript content and lead contact details are encrypted at rest (AES-256-GCM). Legal basis is the customer's; typically Art. 6(1)(b) or (f).
- Voice data — if a visitor uses voice chat, audio is transcribed and synthesized. By default this uses EU providers; US voice providers run only after the visitor's explicit consent (see § 6).
- Operational logs (timestamps, error diagnostics, coarse usage counters) — to run, secure and bill the service. Legal basis: legitimate interest, Art. 6(1)(f).
We do not sell personal data. We do not run third-party advertising or tracking on this site.
4. Where your data lives
EU by default. Our infrastructure runs on Hetzner Online GmbH servers in Germany. Conversation data, lead data, uploaded knowledge-base documents and voice recordings are stored there. AI inference defaults to EU providers (see § 5).
5. Sub-processors
We use a short, deliberate list of sub-processors:
- Hetzner Online GmbH (DE) — hosting.
- Mistral AI (FR) — language-model inference, speech-to-text and text-to-speech (EU default).
- Stripe Payments Europe, Limited (IE) — payments.
- OpenRouter, Inc. (US) — optional model routing, only where a customer selects a non-EU model.
- ElevenLabs, Inc. (US) and Fish Audio (US) — optional premium voices, opt-in only, gated behind visitor consent (§ 6).
The current list is always available on request and in the DPA annex. We notify customers of changes in advance.
6. International transfers
By default, no personal data leaves the EU. Where a customer enables a US-based AI provider (for example a premium voice), the widget asks the visitor for explicit consent before the first use, relying on Art. 49(1)(a) GDPR. Declining keeps the conversation fully EU-resident — the feature simply stays off.
7. Retention
Conversation retention is configured per widget by the customer: session-only (nothing persists after the tab closes), or 7 / 30 / 90 / 365 days. Account and billing data are kept for the life of the contract plus statutory retention periods (e.g. German commercial and tax law). Backups roll off automatically. When data is no longer needed, we delete or irreversibly anonymise it.
8. Security
TLS everywhere; transcripts and lead PII encrypted at rest (AES-256-GCM) with cluster-level key management; strict service-to-service authentication; role-based access; audit trails on conversation access; rate limiting and abuse controls at the edge. Details in the DPA (technical and organisational measures).
9. Your rights
You have the rights of access, rectification, erasure, restriction, portability and objection (Art. 15–21 GDPR), and the right to withdraw consent at any time with effect for the future. Write to nao@openalice.eu — we answer within one month. You may also lodge a complaint with a supervisory authority; competent for us is the authority of the German federal state named in the Impressum.
10. Automated decision-making
Lily is an AI assistant, and conversations are AI-generated (see the AI disclosure) — but we make no automated decisions with legal or similarly significant effect on you. Escalation to a human is always available where the customer has enabled it.
11. Cookies & local storage
Covered in the Cookie notice. Short version: functional cookies only, no ad trackers.
12. Changes
We will update this policy as the service evolves and never quietly reduce your protections. Material changes are announced to customers by email and dated here.