Privacy Policy
1. Who is responsible, and for what
Modus Altos Mikhail Kushnir, NIP 9452325283, REGON 543982920, ul. Partyzantów 8/2, 31-435 Kraków, Poland. Questions about data: mikhail@agenticos.agency.
There are two different roles here, and mixing them up is what makes policies confusing:
- We are the controller for data about you as our client — your account, your payments, our server logs.
- We are the processor for data about your audience that you put into the service — the people who comment on your posts or write to you. There, you decide what happens; we only carry it out. The data processing agreement under Article 28 GDPR applies automatically.
We have not appointed a Data Protection Officer. We are not required to: we are a small company, our core activity is not large-scale monitoring of people, and we do not process special categories of data.
2. What we process, why, and on what legal basis
Each purpose has its own basis. Where the basis is our legitimate interest, the interest itself is named — a policy that says only "legitimate interest" says nothing.
Running your account
Data: name, email, password stored only as a hash, your language
and theme, the organisation and brands you belong to.
Basis: performance of the contract (Art. 6(1)(b) GDPR).
Required? Yes — without an email address we cannot create an
account or let you back into it.
Doing the work you asked for
Data: what you upload — business description, products, images,
video, content plan — plus access tokens for the social accounts you
connect, and the comments, messages and post metrics we fetch for
you.
Basis: performance of the contract. For personal data belonging to
your audience we act on your instructions as processor.
Required? Yes for the features you use; you decide which
ones.
Payment and accounting
Data: plan, invoices, what was spent and when. Card details
never reach us and are never stored in our system — they go straight
to the payment provider.
Basis: contract, and legal obligation for the tax records
(Art. 6(1)(c)).
Keeping the service working and safe
Data: error and request logs, sign-in attempts, spend records.
Basis: legitimate interest (Art. 6(1)(f)) — the interest is
keeping the service running, finding faults, billing correctly and
detecting abuse of accounts. We keep these logs short and do not use
them to build a profile of you.
Improving the product from anonymised statistics
Data: results of published posts, turned into aggregates.
Basis: legitimate interest — the interest is making the
product's recommendations better for everyone who uses it. We work on
aggregates, never on individual rows; we do not show a figure for a group
smaller than five businesses; and we never publish, sell or pass on the
numbers of a named business.
Your control: a switch in Settings turns it off for you
(Art. 21 GDPR).
Showing your work as an example
Data: the material you made, and your brand name next to it.
Basis: your consent (Art. 6(1)(a)) — off by default, given by a
switch in Settings, and withdrawable at any time with the same
switch. Withdrawing does not affect what was lawful before.
Emails we send
Data: your email address.
Basis: contract for service emails (verification, password reset,
receipts, notices about changes) — these you cannot switch off while you
have an account. Anything promotional goes only with your consent and has
an unsubscribe link.
3. Automated decisions
The service acts on its own: it plans content and, in autopilot mode, prepares posts and replies. Those decisions are about content, not about people — nothing here decides whether someone gets a service, a price or a job.
We do not carry out automated decision-making producing legal or similarly significant effects on a person in the sense of Article 22 GDPR, and we do not profile the people in your audience.
Autopilot never publishes without approval unless you switch that on yourself, and you can switch it back at any moment.
4. Separation between brands
Each brand's data is stored separately rather than in one shared pile: library, posts, inbox, leads, analytics and media belong to a specific brand. A team member sees only the brands they have been given access to.
5. Who the data goes to
To carry out your task, data is passed to service providers:
- Model providers — the task text and the images needed to generate.
- Social platforms — what you publish or send.
- Object storage — media files.
- Payment provider — payment details, which do not pass through us.
- Email delivery — your address and the message.
Every one of them is named, with what they receive and where they sit, on the sub-processors page. We do not sell data and we do not share it for anyone else's advertising.
We also disclose data where the law requires it — a lawful request from an authority — and we tell you when we are allowed to.
6. Transfers outside the EU
The servers holding your data are in Germany. Some providers process data in the United States — the page above says which. For those, transfers rely on the European Commission's standard contractual clauses, or on the provider's certification under the EU-US Data Privacy Framework where it has one. You can ask us for a copy of the safeguards for any particular provider.
7. How long we keep it
- Account and brand data — while the account exists, then deleted within 30 days of deletion, except what we must keep by law.
- Generated media — 90 days by default, then deleted automatically.
- Temporary publishing files — 1 day.
- Access tokens — until you disconnect the account, and they are encrypted at rest.
- Invoices and tax records — 5 years from the end of the tax year, because Polish law requires it.
- Server and error logs — up to 90 days.
- Record of a deletion request — kept as a line in a log, so that we can prove the deletion happened.
8. Your rights
You may ask for access to your data, its rectification, erasure, restriction of processing, portability in a machine-readable form, and you may object to processing based on our legitimate interest. Where processing is based on consent, you may withdraw it at any time — the switches in Settings do exactly that, and withdrawal does not make what happened before unlawful.
Write to mikhail@agenticos.agency. We answer within one month; if a request is complex we may extend that by two months and will tell you why.
Account deletion is also self-service: Settings → Delete account. It asks you to type a confirmation phrase, tells you beforehand exactly what will be removed, and revokes the tokens at the platform before deleting our copy.
If you think we handle your data wrongly, you can complain to the Polish supervisory authority — Prezes Urzędu Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl — or to the authority where you live.
9. Client links
Approvals and reports can be opened by someone without an account through a link. Such a link is tied to one brand, has an expiry date and can be revoked. It is not indexed by search engines. Whoever holds the link sees the data, so treat it like a password.
10. Security
Connections are encrypted. The session cookie is not readable by JavaScript and is sent only over a secure connection. Passwords are stored as hashes. Sign-in attempts are rate-limited. Access tokens for your social accounts are encrypted at rest. Share-link tokens are stored only as hashes and cannot be recovered from storage. Backups are kept in object storage separate from the server, sent over an encrypted connection and encrypted at rest by that provider — we do not add a second layer of our own on top, and we would rather say so than imply more than we do.
If a breach ever puts your rights at risk, we notify the supervisory authority within 72 hours and tell you directly where the law requires it.
11. Cookies
Technical only: the session and your theme choice. There are no advertising cookies, no tracking pixels and no third-party analytics. We therefore do not ask for cookie consent — there is nothing to consent to.
12. Children
The service is for businesses and is not directed at children. We do not knowingly create accounts for people under 16.
13. Changes
If we change this policy materially, we give notice by email and in the app at least 14 days before it takes effect. The revision number and date at the top of this page always say which version is in force.