Kroov Privacy Policy

EVA AI TECHNOLOGIES (5 rue Ellenhard, 67000 Strasbourg, France), the publisher of Kroov, is the controller of the processing described in this policy: the processing that concerns Kroov users and website visitors.

For data you entrust to us about your own customers and contacts (messages received by the support assistant, people called by the phone assistant, the content of your knowledge bases), you, the Kroov customer, are the controller; Kroov processes it on your behalf, as a processor, under the data processing agreement annexed to the terms of sale.

Contact for any question about your data: support@kroov.ai.

Depending on how you use the service:

• Your account: name, email address, password (stored hashed) or Google sign-in, language, time zone, and your acceptance of our terms (version, date, IP address, browser).
• Your workspace: organization, members, roles, invitations, settings.
• The website of your business that you ask us to analyse: public pages read, screenshots, logo, fonts and images found, stored in your brand sheet.
• Your content: messages exchanged with the assistants, instructions, uploaded files, knowledge bases, posts, images and videos produced.
• The assistants' memory: what you ask them to remember, and what they remember on their own if you allowed it, including preferences inferred from your choices; visible, editable and deletable from "Memory".
• The social and app accounts you connect (LinkedIn, X, Facebook, Instagram, TikTok, YouTube, WhatsApp, Gmail or Outlook through Pipedream…): encrypted connection credentials, account name and picture, posts made from Kroov.
• Your customers' exchanges with the support assistant: name, email address or number, messages, attachments, replies sent.
• Calls made by the phone assistant: number called, mission, duration, transcript and summary. Audio is not recorded.
• Billing: plan, payments, invoices, billing address and VAT number (collected and kept by Stripe; we never see your card number).
• Technical data: IP address, browser, log of actions taken in the workspace (audit log), operating logs.
• Sign-up fraud prevention: the IP address and a device identifier (kroov_device cookie) of an account's first session, and Google reCAPTCHA's bot check on the sign-up and invitation pages.

• Providing the service: account, workspace, brand analysis, content production and publishing, assistants, integrations. Basis: performance of the contract.
• Collecting payments, invoicing, bookkeeping. Basis: performance of the contract and our legal obligations (keeping accounting records).
• Securing the service, preventing fraud and abuse, keeping the audit log. Basis: our legitimate interest in protecting the service and its users.
• Preventing automated sign-ups and abuse of free credits (one grant per device, three per IP address over 30 days): Google reCAPTCHA check at sign-up and invitation, device identifier and IP address. Basis: our legitimate interest in protecting the service against fraud.
• Writing to you about the service: verification codes, invitations, security alerts, notifications, invoices. Basis: performance of the contract. We do not send marketing newsletters.
• Measuring the audience of the website's public pages (Google Analytics, anonymised IP address), only if you accept it in the cookie banner. Basis: your consent.
• Answering requests from authorities and complying with the law. Basis: legal obligation.

Kroov relies on artificial intelligence models provided by third parties (see below): your instructions and the content needed for a production are sent to them for the time it takes to process it. Kroov does not train any model on your data, and our providers' API terms exclude using that data to train their models.

Images and videos produced by Kroov carry a machine-readable marking stating that they were generated by AI. No decision producing legal effects for you is taken solely on the basis of automated processing. If you set the support assistant to send automatically, its replies go out without human review: that is your choice, reversible at any time.

We do not sell your data or use it for advertising. It is accessible to the members of your workspace according to their rights and the visibility chosen (personal, shared, organization), to the Kroov team when needed for support or security, and to our processors, each for its role:

• Hosting: Google Cloud, in the European Union.
• Artificial intelligence model providers (text, images, video, voice): producing the content, replies and calls you request.
• Google reCAPTCHA and Google Analytics: bot check at sign-up, audience measurement if you accept it (under Google's privacy policy and terms: https://policies.google.com/privacy, https://policies.google.com/terms).
• Stripe: payments, invoicing, VAT calculation.
• Technical providers: telephony, sending and receiving emails, web search, collection of public social media data, connection of third-party apps (Gmail, Outlook…).
• Meta, LinkedIn, X, TikTok, YouTube (Google), Telegram: posts and messages on your accounts, at your request.

The named list of our processors, with their country and the safeguard covering each transfer, is available to our customers in the app (Settings › Security & data) and sent to anyone who asks for it at support@kroov.ai.

We may also disclose data where the law requires it.

If you connect a YouTube channel, Kroov asks Google for a single permission ("youtube.force-ssl": manage your YouTube videos and comments). With it, Kroov only accesses:

• your channel: its ID, name, custom URL and picture;
• the videos you publish from Kroov: uploading them, their processing status and deleting them, at your request;
• for those videos only, during the 31 days after they are published: their figures (views, likes, comment count) and their comments (text, date, name and channel ID of their author).

Kroov does not read any other video, nor your subscriptions, history, playlists or any other data in your Google account. If you sign in to Kroov with Google, we also receive your name, email address and profile picture, used only to create your account and sign you in.

This data is used only for the features you use in Kroov: publishing your videos, showing their results and suggesting replies to comments. Each new comment is sent to our AI model providers, together with the video it belongs to and your brand sheet, to draft a suggested reply; no reply is posted on YouTube without your approval. Neither Kroov nor these providers use this data to train AI models.

We do not sell data received from Google, do not use it for advertising or to determine creditworthiness, and only transfer it to the processors needed for these features (hosting and AI models, see "Who receives your data"). The Kroov team does not read it, except with your explicit consent (for example to answer a support request), for the security of the service (investigating abuse) or to comply with the law.

Kroov's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.

By connecting YouTube, you also agree to the YouTube Terms of Service (https://www.youtube.com/t/terms); Google processes your data under its own privacy policy (https://policies.google.com/privacy).

Retention: a comment is deleted 30 days after it was last refreshed; figures are kept as long as your authorization remains valid (we check it every hour).

Removing access: removing the channel from the "Accounts" page in Kroov immediately erases our access tokens, its comments, figures, name and picture, and revokes Kroov's authorization at Google; only the record of your posts (their link) remains. Deleting your Kroov account does the same for the channels you connected personally, and for all of the workspace's channels if the whole workspace is deleted. You can also remove access at any time from your Google account's security settings page (https://security.google.com/settings/security/permissions): the channel's data is then deleted within 30 days.

Kroov is hosted in the European Union. Some of our processors are established outside the European Union, notably in the United States and South-East Asia, or process part of the data there. These transfers rely on the European Commission's adequacy decision for companies certified under the EU–US Data Privacy Framework or, failing that, on the European Commission's standard contractual clauses, a copy of which you can obtain at support@kroov.ai.

Your data is kept as long as your account exists, except the technical data below, deleted automatically every night:

• audit log (who did what in the workspace): 13 months;
• content exchanged with AI models to produce your posts (instructions, intermediate text, raw answers): 6 months; their cost and volume remain for billing;
• log of emails sent: 1 year;
• notifications received from connected services: 30 days;
• expired sign-in sessions and verification codes: 7 days after they end;
• IP address and device identifier recorded at sign-up: 12 months, including after the account is deleted (otherwise deleting an account would allow receiving the free credits again);
• call transcripts and summaries: according to your setting, 30 days by default (0 to keep none);
• library files: according to your setting, 30 days by default, except pinned files;
• comments received on YouTube: 30 days after they were last refreshed; a YouTube channel's data (comments, figures, name and picture): deleted as soon as it is removed, or within 30 days if you remove access from Google.

Invoices and accounting records are kept for ten years, as French commercial law requires. Database backups are deleted on rotation, within 14 days.

You can delete your account from your settings. Your address is released immediately and all your sessions are closed, then your data is erased, not merely deactivated:

• if you were alone in your workspace: the whole workspace (brand sheet, posts, files, calls, support requests, memory);
• if other members remain: your personal data (conversations, personal memory, files, personally connected accounts, settings). What belongs to the workspace (posts, brand sheet, calls, support requests, organization memories) remains available to the other members.

Deletion is refused while a paid subscription is running or while you are the only owner of a workspace where others work. The record of your acceptance of our terms is kept, without IP address or browser, as proof; sign-up signals (IP address, device identifier) remain until their 12 months are over.

You have the right to access, rectify, erase, restrict, object to and port your data, to withdraw your consent at any time, and to set instructions on what happens to your data after your death.

From the application, you can already view and export your data ("My data"), export your memory (Markdown or JSON), correct your brand sheet and memories, and delete your account. For any other request, write to support@kroov.ai; we answer within one month.

If you believe your rights are not respected, you can lodge a complaint with the CNIL, the French data protection authority (www.cnil.fr, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France).

We protect your data, and sensitive data in particular (access tokens for your connected accounts, data received from Google and social networks, exchanges with your customers), with the following measures:

• Encryption in transit: every connection to the service is encrypted (HTTPS); the database only accepts encrypted connections.
• Encryption at rest: the database, its backups and files are encrypted on Google Cloud servers, in the European Union.
• Application-level encryption of secrets: access and refresh tokens for your connected accounts (YouTube included) and the credentials of your integrations are encrypted a second time by the application (AES-256-GCM) before being stored; the key is kept separately, in Google Secret Manager. Google sign-in tokens are encrypted too. No token is ever sent back to your browser.
• Restricted access: the database can only be reached with a Google Cloud (IAM) authorization; files are kept in private storage, closed to any public access, and served through temporary links valid for 30 minutes at most; within the application, every access is checked against your workspace membership, your role and the visibility of the data (personal, shared, organization).
• Minimisation: we only ask each service for the permissions we need (a single one for YouTube); removing an account erases our tokens and, for YouTube, revokes access at Google; the retention periods given above are enforced by automatic purges.
• Traceability: sensitive actions (connecting, removing or sharing an account, denied access) are written to the audit log, kept for 13 months.
• Abuse protection: rate limiting, signature verification of notifications received from connected services.
• Incidents: in the event of a breach of your data, we notify the CNIL within 72 hours where the law requires it, and inform you without undue delay if it poses a high risk to you.

We may change this policy. The date of its version appears at the top of the page; for each significant version, you are invited to read it at your next sign-in.