PromptOps — Privacy Policy

Document type: Information notice under Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) Version: 2.1 Effective date: 1 November 2026 Status: published 28 October 2026, in force from 1 November 2026. Until then, version 2.0 applies.

This notice replaces every earlier privacy notice for PromptOps. If you have seen a different one — on another page, in an older version of the app, or on a different domain of ours — this is the one that applies from the effective date above. Previous versions remain available in the archive linked at the end.

Summary
Who is the controller
Scope
How PromptOps works, and why that matters for your privacy
Data that stays only on your device
Processing activities
Data we do not collect
Recipients and sub-processors
International transfers
Retention
Your rights
How to exercise your rights
Security
Cookies and similar technologies
Children
Automated decision-making
Changes to this policy
Contact and complaints
Version history

1. Summary

This is a plain summary. The binding detail is in sections 5 to 10.

Your source code is not uploaded to us. Code embeddings for project context are computed on your own device.
A lot of what you do stays local. Terminal output, your project context index, and your AI provider credentials are stored on your device and are not sent to us.
Some prompt content does reach our servers. Specifically: entries you save in the Prompt Library (that is the point of the feature), and — currently — the prompt text of active sub-agents, which is stored as part of session state. We explain this openly in section 6.3 rather than claiming otherwise.
When you use an AI provider, your prompts go to that provider, not to us. PromptOps runs the provider's own tool on your machine, using your own account. What that provider does with your data is governed by that provider's terms.
We measure how much you use the product, per user: prompt counts, hours, presence, tokens. This is not anonymous.
In a team, your teammates see some of your activity: whether you are online, your office avatar and desk and, unless you switch it off, how many AI tokens you used today. They do not see your prompts, your terminals or your hours. See sections 6.15 and 6.16.
Daily token totals are collected only if you use Teams. If you do not belong to a team, your token usage stays on your device.
Team chat is end-to-end encrypted. Messages are encrypted on your device and we store only the encrypted form, with the exception explained in section 6.17.
We do not use your content to train AI models, do not sell it, and do not use it for advertising.
Your account data is stored in the European Union (AWS, Milan region). Some service providers are outside the EU.

2. Who is the controller

SHELLONBACK SRL is the data controller.

Registered office: Via Stupinigi 29, 10092 Beinasco (TO), Italy VAT number, tax code and Company Register (Registro Imprese) number: 13331060015 Registro Imprese di Torino no. 13331060015 | REA no. TO-1355500 | Share capital EUR 10,000 Email for privacy matters: luca.mangiacotti@shellonback.com PEC: shellonback@pec.it

Data Protection Officer: not appointed. None of the three cases in Art. 37(1) GDPR applies: we are not a public authority; our core activities do not consist of regular and systematic monitoring of data subjects on a large scale; and we do not process special categories of data on a large scale. This assessment is recorded in our records of processing and is revisited whenever the nature or scale of processing changes. Data protection enquiries reach us at the address below.

3. Scope

This policy covers personal data processed in connection with:

the PromptOps desktop application;
the web application at manager.promptops.it;
the mobile remote application and relay service;
the backend services and APIs, including team features, integrations, the plugin registry, and organisation sign-in (SSO) and provisioning (SCIM);
the website promptops.it.

It does not cover the processing carried out by third parties you choose to use through PromptOps, such as AI providers. Those are governed by their own privacy notices — see section 4.3.

4. How PromptOps works, and why that matters for your privacy

4.1 PromptOps is an orchestrator

PromptOps runs AI coding tools that are installed on your machine, in terminal processes it controls. When you send a prompt, PromptOps writes it into the tool's terminal. The tool then contacts its own vendor's servers, using your account or API key.

The practical consequence: for ordinary AI use, your prompt does not pass through our servers. It goes from your machine to the provider you chose.

4.2 What we can and cannot see

We can see what our own applications send to our own backend: your account, your session and workspace structure, your prompt library, your usage metrics, and the specific items listed in section 6.

We cannot see the content of your terminals, your files, or the conversations you have with an AI provider, except in the specific cases described in section 6.3 and 6.9.

4.3 The provider relationship is yours

When you use OpenAI/Codex, Anthropic/Claude Code, Google Gemini, GitHub Copilot, xAI or any other provider through PromptOps, that provider processes your prompts and any file content you include as an independent controller, under its own terms and privacy notice. We do not control whether it retains your data or uses it for training. See AI and Third-Party Providers.

5. Data that stays only on your device

The following is stored locally on your computer and is not transmitted to Shellonback:

Data	Where	Protection
Terminal output buffers — the recent contents of each terminal, including AI responses, commands and anything else displayed on screen (up to about 256 KB per terminal)	Application data folder, `terminal-buffers/`	Encrypted at rest using the operating system's secure storage facility (Electron `safeStorage`). If that facility is unavailable on your system, the file is written unencrypted.
Project context and knowledge index — the local index PromptOps builds of your project	`.promptops/` folder inside your project (git-ignored)	Not encrypted; on your device only
Code embeddings — numerical representations of your code used for local search	Your device	Computed on-device; the code is not uploaded to compute them
Local session store	Application data folder	Not encrypted
SSH connections you configure (host, user name, password or private key)	Application data folder	In the current desktop application (2.x) not encrypted — see the note below
Your authentication token	Application data folder	Encrypted using operating system secure storage, with an unencrypted fallback if unavailable
AI provider API keys and credentials	Either in the provider CLI's own configuration folder, or in PromptOps' local configuration	See the note below
AI Accounts — extra sign-ins to the same provider: their names, notes and configuration folders	Application data folder; each account's credentials stay in its own provider configuration folder	Not encrypted by PromptOps; on your device only. Only an internal identifier of the account a session was started with is synchronised, inside the session configuration, which is encrypted at rest (section 6.3)
Plugin credentials — tokens you enter for plugins such as ClickUp, Jira or Trello	Application data folder	Encrypted (AES-256-GCM, key held in the operating system keychain). On Linux systems without a keychain service, stored unencrypted with owner-only file permissions. Plugins contact their service directly from your device
Today's token counter — the running total of AI tokens used today on this computer	Application data folder	Not encrypted; on your device. It is sent to us only if you use Teams: see section 6.16

SSH connections — current state. The previous desktop application encrypted saved SSH passwords and keys. The current one (2.x) stores them in plain text in its data folder. They are never sent to us, but anyone with access to your user account on the computer can read them. We are moving them to the operating system's secure storage; until then, prefer SSH keys protected by a passphrase managed by your SSH agent.

API keys — current state. The authentication token is encrypted at rest. Two configuration files — the FCC provider configuration and the voice configuration — currently store API keys unencrypted on disk (the voice configuration file has restrictive file permissions). We state this plainly rather than overstating our protections. We are moving them to the same encrypted storage already used for SSH credentials and the authentication token.

Because this data is on your device, your own device security (disk encryption, screen lock, malware protection) determines its protection. Deleting your account does not delete it: you control it.

6. Processing activities

For each activity: what data, why, on what legal basis, whether it is required, where it comes from, who receives it, and how long it is kept.

6.1 Account registration and authentication


Data	First name, last name, email address, username, password (stored only as a bcrypt hash), and optionally: biography, avatar image, location, website, GitHub username, nationality. If you use social login: the identity provider's name and your identifier with that provider, plus the profile fields it returns (typically name and email).
Purpose	Creating and managing your account; authenticating you; letting you recover access.
Legal basis	Performance of a contract (Art. 6(1)(b) GDPR).
Required?	Email, name and password (or a social identity) are required to have an account. Profile fields are optional.
Source	You; or, for social login, the identity provider you chose.
Recipients	Our hosting provider (AWS, EU); the identity provider, for social login.
Retention	Until you delete your account — see section 10.


Data	The type of document accepted, its version, whether it was accepted, the date and time, your IP address and your browser/application user agent.
Purpose	Demonstrating that you accepted the Terms, the EULA and the Privacy Policy, and recording optional consents (marketing, product updates).
Legal basis	Legal obligation and accountability (Art. 6(1)(c) and Art. 5(2) GDPR); legitimate interest in evidencing contractual acceptance (Art. 6(1)(f)).
Required?	Yes — the record is generated automatically when you accept.
Recipients	Hosting provider (AWS, EU).
Retention	10 years after account deletion. The period matches the ordinary limitation period under Italian law (art. 2946 Civil Code): consent records exist to prove compliance, and they need to outlast the window in which that proof could be required.

6.3 Sessions, workspaces and sub-agents (cloud synchronisation)

This is the section that deserves your attention.


Data	Session names; workspace paths (encrypted at rest in the sessions table); project paths (currently not encrypted in the workspaces table); device-workspace associations (encrypted); the structure of your sub-agents, including their role, title and status. *And: the prompt text of active* sub-agents.**
Purpose	Restoring your sessions across devices and after restart; showing your workspace structure; making the mobile remote feature work.
Legal basis	Performance of a contract (Art. 6(1)(b)).
Required?	Yes, for the desktop application. Session and workspace structure is synchronised so that your work can be restored; there is currently no way to use the application with synchronisation switched off.
Recipients	Hosting provider (AWS, EU).
Retention	While the session or workspace exists. Archived sub-agent data: about 30 days.

Important detail, stated openly.

The prompt text of sub-agents that are archived is removed — both by the desktop application before sending, and by the server before storing.
The prompt text of sub-agents that are active is currently transmitted and stored as part of session state, in plain text.
This is inconsistent with our intended design, and we are treating it as an item to correct.

We are working to remove this: the intended behaviour is that no runtime prompt text is stored on our servers, and the archived case already works that way. Until the active case matches, this section describes what actually happens rather than what we intend.

6.4 Prompt Library


Data	The full text of the prompts you save: body, system prompt, notes, variables, sub-agent prompt definitions.
Purpose	Storing, organising, versioning and reusing your prompts across devices — this is the purpose of the feature.
Legal basis	Performance of a contract (Art. 6(1)(b)).
Required?	Optional: only what you choose to save is stored.
Storage	Stored in plain text in our database, so that search and sharing work. If you would not put something in a shared document, do not put it in a saved prompt.
Recipients	Hosting provider (AWS, EU).
Retention	Until you delete the prompt or your account.

If you put sensitive information into a saved prompt, that information is stored on our servers. Please don't put credentials in prompts.

6.5 Device registration


Data	A device identifier derived from hardware characteristics (a SHA-256 hash), the device name, operating system information, and the application version. Transmitted with requests as a device header.
Purpose	Associating sessions with devices; managing licences and device limits; enforcing minimum supported application versions; security (recognising unexpected devices).
Legal basis	Performance of a contract (Art. 6(1)(b)); legitimate interest in security and licence enforcement (Art. 6(1)(f)).
Required?	Yes, for the desktop application.
Retention	While the device is associated with your account.

6.6 Product usage metrics


Data	Number of prompts sent per day; hours of use, with session and source; daily presence (the first and last time you were seen each day); the time you were last seen; token statistics per session; a daily total of AI tokens per device, only if you use Teams (section 6.16); ranking position if you take part in the ranking feature; the platforms, application versions and tool in use.
Purpose	Making the product's own usage statistics and ranking features work; understanding how the product is used in order to improve it; detecting abuse.
Legal basis	Performance of a contract for the statistics displayed back to you (Art. 6(1)(b)); legitimate interest for product improvement and abuse prevention (Art. 6(1)(f)); consent for participation in the public ranking, which is opt-in.
Required?	The metrics that power features you use are part of those features. For the portion we process on the basis of legitimate interest — product improvement — an opt-out is being added. Until it ships, you can ask us to exclude you by writing to the address in section 18, and we will do it manually.
Recipients	Hosting provider (AWS, EU). Within a team, the limited items in section 6.15 are visible to your teammates.
Retention	24 months, then deleted automatically. Daily prompt counts and ranking snapshots are kept while you have an account, because they make up your ranking history.

These metrics are individual and linked to your account. They are not anonymous. Where we publish aggregate figures (for example a public ranking you opted into), those are derived from individual records that continue to exist.

Ranking. The ranking is visible only to signed-in users, and only if you opted in; registering one of your teams in the team ranking also enters you. It shows your username, name, avatar, nationality, prompt counts and badges, and the "study the opponent" view adds your activity statistics (active days, best day and month, averages). A team's score is the sum of its members' prompt counts; the individual counts of members who have not opted in are never shown. Monthly podium places are kept in the hall of fame even if you later leave the ranking: ask us and we will remove yours. If you have not uploaded an avatar, the image shown to others is generated by the ui-avatars.com service from your name (section 8).

6.7 Voice input (optional feature)


Data	Audio recorded from your microphone, and its transcription.
Purpose	Converting speech to text so you can dictate prompts.
Legal basis	Consent (Art. 6(1)(a)) — the feature is used only when you activate it.
Required?	No. The feature is optional.
Recipients	When the on-device transcription model is installed and returns text, no one: the audio stays on your device. Otherwise — for example while that model is still downloading — the audio goes to the next available option: a proxy on our backend that forwards it to Groq, then Groq, Google or OpenAI with your own key, or your operating system's speech recognition. Cloud providers are outside the EU: see section 9.
Retention	The audio file is written to a temporary folder on your device and deleted after transcription. What the transcription provider retains is governed by that provider's own terms — we do not control it, and we would rather say so than guess.

Your voice is personal data. If this matters to you, do not use the voice feature, or use a locally-running transcription option if one is available on your system.

6.8 Email: transactional and marketing


Data	Email address, name; for newsletter subscriptions also IP address and user agent at the time of subscription.
Purpose	(a) Transactional: email verification, password reset, security alerts, service notices. (b) Marketing and product updates: newsletter, product news, the Morning digest.
Legal basis	(a) Performance of a contract (Art. 6(1)(b)) and legal obligation. (b) Consent (Art. 6(1)(a)), given separately and revocable at any time.
Required?	(a) Yes. (b) No — entirely optional.
Recipients	Email delivery provider (AWS SES; alternatives may be used).
Retention	Subscription records until you unsubscribe, plus a record of the opt-out to ensure we do not contact you again.

Every marketing email contains a one-click unsubscribe link. You can also manage preferences in your account.

6.9 Mobile remote control


Data	The input and output of the terminal you are controlling — which may include prompts, AI responses, commands and anything else displayed; connection metadata (IP address, user agent); pairing information.
Purpose	Letting you control a desktop session from your phone.
Legal basis	Performance of a contract (Art. 6(1)(b)) — the feature is opt-in and requires you to approve a pairing.
Required?	No.
Technical detail	The connection is protected in transit by TLS. It is not end-to-end encrypted: the relay service processes the data in transit.
Retention	Connection logs 90 days. Prompt content is not written to relay logs.

6.10 Support and feedback


Data	The content of your message, your account details, and any technical information or images you choose to include (up to five images, stored in AWS S3 in the EU). Nothing is attached automatically.
Purpose	Answering you and resolving the issue.
Legal basis	Performance of a contract (Art. 6(1)(b)); legitimate interest in improving the product (Art. 6(1)(f)).
Recipients	For feedback about a third-party plugin: that plugin's publisher, who receives your first and last name, your message and your images — not your email address. The form tells you who will read it. Otherwise only us.
Retention	24 months from closure of the request

6.11 Security, audit and abuse prevention


Data	IP addresses, user agents, timestamps, actions performed, and — for administrative actions — the previous and new values of changed fields. Application and server logs.
Purpose	Protecting accounts and the service; investigating incidents; detecting and preventing abuse; establishing, exercising or defending legal claims.
Legal basis	Legitimate interest (Art. 6(1)(f)); legal obligation where applicable (Art. 6(1)(c)).
Recipients	Hosting provider; centralised logging providers (see section 8).
Retention	12 months, then deleted automatically

Ranking moderation. To keep the ranking fair we may review the accounts at the top of it. An administrator can look at an account's email, its daily prompt series over the last 60 days and the names of its recent sessions, assisted by an automatic tool that flags unusual patterns. The tool never acts on its own: any suspension from the ranking is decided by a person, notified to you by email with its reasons, and can be appealed from the application. Suspension records are kept as long as the account exists, to handle appeals and repeat cases.

6.12 Website: analytics and measurement


Data	A session identifier, pages visited, referrer, UTM campaign parameters, user agent, viewport size; and, where you consent, data collected by Google Tag Manager and Google Analytics 4.
Purpose	Understanding how the website is used and measuring campaigns.
Legal basis	Consent (Art. 6(1)(a)), collected through the cookie banner. Strictly necessary technical storage does not require consent.
Required?	No. Analytics and profiling categories are disabled until you accept them.
Recipients	Google (Tag Manager, Analytics 4); our own analytics endpoint.
Retention	14 months in GA4; 14 months in our own analytics

See section 14 and the Cookie Policy.

6.13 Billing (not yet active)

No payment processing takes place at the date of this policy: PromptOps is free and no payment provider is integrated. When paid plans are introduced, this section will describe the billing data processed, the payment provider, its role, and the retention required by tax law.

No payment processing takes place today: PromptOps is free and no payment provider is integrated. This section will describe the billing data, the provider and its role before any plan goes on sale.

6.14 Error reports from the desktop application


Data	When the desktop application hits an internal error: a random report identifier, the application version, operating system and processor architecture, the kind of error and the place in our code where it happened, and the time. Linked to your account. Error messages and file paths are removed before sending.
Purpose	Finding and fixing faults.
Legal basis	Legitimate interest in the reliability and security of the application (Art. 6(1)(f)). You may object by writing to us.
Required?	Sent automatically. Reports wait on your device for up to 7 days if you are offline.
Recipients	Hosting provider (AWS, EU).
Retention	14 days

6.15 Teams: membership, presence and the virtual office


Data	The teams you belong to and your role; invitations (the invitee's email, the role offered, who invited, status and expiry — invitations expire after 7 days); whether you are online (derived from the time you were last seen, see 6.6); the look you choose for your office avatar and the desk you pick.
What your teammates see	Your name, username, avatar, role, and whether you are online now — never the time you were last seen; in the virtual office, your avatar look and desk; in the token leaderboard, the items in 6.16. They do not see your prompts, terminals, sessions or hours. Clients of a team see the member list but not the office, the chat or the leaderboard.
Purpose	Making team collaboration work.
Legal basis	Performance of a contract (Art. 6(1)(b)).
Required?	Only if you join a team.
Recipients	Your teammates, as described above; hosting provider (AWS, EU); the email delivery provider, for invitations.
Retention	Membership until you or an administrator remove it; invitation records until the team is deleted.

If your team is your employer. The team owner decides who joins. An employer using PromptOps teams with its staff is responsible for informing them and for complying with employment law on remote monitoring — in Italy, art. 4 of Law 300/1970. See clause 19.3 of the Terms of Service.

6.16 Team token leaderboard


Who it concerns	Only people who use Teams: the owner of a team, or a member of one other than as a client. If you do not belong to a team, we do not keep your token totals: the count stays on your device.
Data	For each day and each of your computers: the total number of AI tokens used, summed over every session, provider and AI account — including any change of provider or account during the day. The computer is identified only by a shortened fingerprint (a hash) of its device identifier.
How it is collected	The desktop application counts tokens locally (section 5) and sends the day's total every few minutes, only when it has grown. It never sends prompts, responses, models or providers. If you do not use Teams, or have hidden yourself, our server discards the total without storing it and the application asks again only after an hour.
What your teammates see	In the virtual office, the internal members of your teams see a ranking of today's totals, highest first. A person appears only if they were active that day — seen online, or with tokens used — so being listed with zero shows that you were online that day.
Purpose	Letting a team see how AI is being used across it.
Legal basis	Legitimate interest of you and your team in sharing usage within the team (Art. 6(1)(f)), balanced by the switch below.
Your choice	The "Show me in the leaderboard" switch, in the leaderboard panel. Turning it off removes you from every team's leaderboard, deletes the totals already stored, and stops storing new ones. You can turn it back on at any time.
Recipients	Your teammates, as above; hosting provider (AWS, EU).
Retention	24 months, like the other usage metrics; deleted at once if you hide yourself or delete your account.

6.17 Team chat


Data we store	Encrypted messages; the conversation they belong to; who sent them and when; which messages each member has read; for each of your devices, its public encryption key, a fingerprint of that key and a label such as "PromptOps Desktop · macOS"; the conversation keys, encrypted separately for each device. Notifications contain the team, the conversation and the sender's name, never the message text.
End-to-end encryption	Messages are encrypted on your device with a key that only the members' devices hold. We cannot read them. The private key of each device never leaves it. If you create a backup file of your keys, it is protected by a password you choose.
Exception	Direct messages sent before end-to-end encryption was introduced (October 2026) were moved into the chat as they were, unencrypted, and remain readable by us.
What teammates see	Members of a conversation see its messages; the internal members of a team see the device labels and key fingerprints of their teammates, so they can verify them.
Purpose	Letting team members talk to each other.
Legal basis	Performance of a contract (Art. 6(1)(b)).
Retention	Until the conversation is deleted, its last member leaves, or the team is deleted. Individual messages cannot currently be deleted. If you delete your account, messages you sent stay in the conversation, attributed to a deleted user.

Video calls. If you connect Google Meet (section 6.19), starting a call from the chat creates a meeting on your Google account and sends its link to the conversation, with your name.

6.18 Projects, tasks and files


Data	Projects, tasks, assignments, comments, mentions and the files you upload (stored in AWS S3 in the EU, downloadable only through links that expire after 15 minutes); notifications about them, which contain the task title, the name of the person acting and, for comments, an excerpt of up to 200 characters (120 in emails).
Purpose	Organising a team's work.
Legal basis	Performance of a contract (Art. 6(1)(b)).
Recipients	The members of the team or project; hosting and email delivery providers.
Retention	Until deleted by the team, or until the team is deleted. If you delete your account, your comments and files stay with the team, attributed to a deleted user.

6.19 Integrations and plugins


ClickUp (built-in integration)	A team administrator can connect a project to ClickUp with their own personal token, stored encrypted and visible to no one else. We then read tasks and comments from ClickUp every few minutes — including the names and email addresses of their assignees and authors, used only to match them with team members — and send back to ClickUp only status changes. ClickUp is a United States company.
Plugins	Plugins such as ClickUp, Jira or Trello keep their credentials on your device (section 5) and contact their services directly from your device, only at the addresses they declare. Those services receive the data the plugin sends them, under their own terms. We store which plugins you installed and their versions, and team-shared plugin settings that contain no credentials.
Plugin registry	Plugins are listed under their publisher's public profile (name, website, avatar and repository). If you publish plugins, that profile is visible to every signed-in user. We download and statically review each plugin's public code before listing it; we never run it on our servers.
Google Meet	Optional, per user. You authorise us on your Google account with the "openid", "email" and "create meeting spaces" permissions. We store your Google email and the access tokens, encrypted. We use them only to create a meeting when you start a call; we send Google no other data. Disconnecting deletes the tokens and revokes them at Google.
Legal basis	Performance of a contract (Art. 6(1)(b)), at your or your administrator's request.
Retention	Until the integration, plugin or connection is removed, or your account is deleted.

6.20 Organisations: single sign-on and provisioning


Data	For accounts managed by an organisation: the organisation you belong to and your role in it; your identity provider's identifiers (Microsoft Entra ID tenant, Google Workspace domain, SAML or SCIM identifiers); the email your provider reports; whether the organisation suspended your access.
What organisation administrators see	The member list — name, email, sign-in method, role and status — and the organisation's audit log: actions taken in the organisation, with who performed them, their email, IP address and browser. They do not see your prompts, sessions, hours or tokens.
Forwarding	If the organisation configures it, organisation events are also sent to a destination it chooses: a security monitoring system (all events) or a Microsoft Teams channel (some events). These events can include emails and the details of the change. The organisation decides the destination and is responsible for that processing.
Legal basis	Performance of the contract with the organisation (Art. 6(1)(b)), and its legitimate interest in managing access (Art. 6(1)(f)). For data processed on the organisation's instructions we act as its processor.
Retention	Membership while it lasts; audit log 12 months.

6.21 In-app messages and invitations


Data	While the application is in use, a periodic signal with the minutes of active use and the interface style; your answers to in-app messages (shown, dismissed, accepted, postponed, and any text you write, which becomes a support ticket, see 6.10); the interface test group you are in, assigned by your account number.
How messages are chosen	A message is shown according to the platform and application version, the interface style, whether you are in the ranking, how many minutes you have used the application and how many prompts you have sent. This selection has no legal or similar effects on you.
Beta programme	If you accept an invitation to test a new version, your email is added to the list of testers and you receive an email with instructions.
Legal basis	Legitimate interest in informing users about the product and collecting their opinion (Art. 6(1)(f)). You can object by writing to us; accepting the beta is your choice.
Retention	Until your account is deleted. Your email leaves the testers list when you delete your account or ask us.

7. Data we do not collect

To be precise about the negatives, each of these has been verified:

We do not upload your source code to our servers for indexing or embedding. Embeddings are computed on your device.
We do not receive your AI provider API keys. They stay on your device.
We do not use third-party analytics SDKs in the application. There is no Sentry, PostHog, Mixpanel or Amplitude in the desktop application, the web application or the backend.
We do not use your content to train AI models.
We do not sell personal data.
We do not use your content for advertising.
We do not read your terminal output, except where you use the mobile remote feature (section 6.9), in which case the relay processes it in transit.
We cannot read end-to-end encrypted team chat messages (section 6.17).
We do not receive the prompts, models or providers behind your token counts (section 6.16).

What we deliberately do not claim: we do not claim that "no prompt ever reaches our servers". Section 6.3 and 6.4 explain exactly which prompt data does.

8. Recipients and sub-processors

We use the following categories of provider.

Provider	Role	Location
Amazon Web Services	Hosting, database, object storage, content delivery	eu-south-1 (Milan, EU) for the main infrastructure
Amazon SES	Transactional email delivery	Configured for the EU region
Postmark / Resend	Alternative email delivery	United States
Groq	Voice transcription; AI text generation for internal features and the news pipeline	United States
OpenAI	Voice transcription fallback; certain AI helper features	United States
Anthropic	Certain AI helper features	United States
Google	Social login; speech recognition; Tag Manager and Analytics on the website	United States
Apple, GitHub, Facebook, LinkedIn	Social login	United States
Slack	Internal operational notifications	United States
Papertrail (SolarWinds)	Centralised application logging	United States
GitHub	Distribution of application updates	United States
ClickUp	Built-in board integration, when a team administrator connects it (section 6.19)	United States
Microsoft	Organisation sign-in (Entra ID); Microsoft Teams notifications, when an organisation configures them (section 6.20)	United States
ui-avatars.com	Generates placeholder avatars from the name of users without one: the name is sent by the browser that displays the image	Outside the EU
Hugging Face	Download of the on-device voice model; no personal data beyond the connection itself	United States

Some recipients are not our service providers but act on their own account:

plugin publishers receive the feedback you send them about their plugin (section 6.10);
services you or your organisation connect — the services contacted by plugins, the security system chosen by your organisation — receive data under their own terms or the organisation's instructions;
your teammates see the items described in sections 6.15 to 6.18.

The onboarding email shows a preview image hosted by YouTube (Google): opening the email loads it from Google's servers.

We are formalising data processing agreements with each of these providers under Art. 28 GDPR. Write to us for the current status of any specific one.

We also disclose data where required by law, to a competent authority, or where necessary to establish, exercise or defend legal claims.

9. International transfers

Your account data and the main application data are stored in the European Union (AWS, Milan region).

Some of the providers in section 8 are established outside the European Economic Area, principally in the United States. Transfers to them require a valid transfer mechanism under Chapter V GDPR — an adequacy decision, Standard Contractual Clauses, or another safeguard.

For providers established in the United States, we rely on the EU-US Data Privacy Framework where the provider holds an active certification, and on Standard Contractual Clauses together with a transfer impact assessment where it does not. We are in the process of documenting this provider by provider; until that work is complete, we prefer to state it plainly rather than imply a level of formalisation we have not yet reached. You can ask us for the current position on any specific provider.

You may request a copy of the safeguards in place by writing to us.

10. Retention

Data	Retention
Account data	Until account deletion
Sessions and workspaces	While they exist; archived sub-agent data about 30 days
Prompt Library	Until you delete the entry or your account
Usage metrics, including daily token totals (Teams users only)	24 months, then deleted automatically. Daily prompt counts and ranking snapshots: while you have an account
Audit and security logs, including organisation audit logs	12 months, then deleted automatically
Desktop error reports	14 days
Team chat, tasks, comments and files	Until deleted by the team or conversation, or the team is deleted
Integrations, plugin installs, Google Meet connection	Until removed, or your account is deleted
Ranking suspensions	While the account exists
Consent records	10 years after account deletion
Newsletter subscription	Until unsubscribe, plus a suppression record
Support correspondence	24 months from closure of the request
Relay connection logs	90 days
Backups	30 days rotation. A deletion request is applied to live systems immediately and works through backups within this window.
Accounting records (when billing starts)	10 years, as required by Italian law (art. 2220 Civil Code)

On account deletion, in a single operation, we:

anonymise your profile (name, username, email, biography, avatar, links, last-seen time, platforms, preferences);
delete your usage metrics and daily token totals, your saved prompts, your registered devices, your plugin installs, your Google Meet connection, your answers to in-app messages, your likes and stars, your email subscriptions, and your membership of teams and projects;
remove your email from the beta testers list and from any message audience list.

What stays, attributed to a deleted user: messages, comments and files you contributed to a team, which belong to the team's shared work; the public encryption keys of your chat devices and your place in existing conversations, without which your teammates could no longer decrypt past messages (a public key reveals nothing about the messages); support tickets (24 months); consent records, audit and security logs, ranking suspensions, and anything we must keep by law or to defend legal claims.

Synchronised sessions and workspaces are kept, encrypted at rest and attached only to the anonymised account; we are adding their permanent deletion. Ask us and we will delete them by hand.

Data on your own device is not affected.

11. Your rights

Under the GDPR you have the right to:

Access (Art. 15) — obtain confirmation of whether we process your data, and a copy of it;
Rectification (Art. 16) — correct inaccurate or incomplete data;
Erasure (Art. 17) — have your data deleted, in the cases provided by law;
Restriction (Art. 18) — have processing limited, in the cases provided by law;
Portability (Art. 20) — receive the data you provided, in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible;
Object (Art. 21) — object at any time to processing based on legitimate interest, on grounds relating to your particular situation, and object at any time and without justification to processing for direct marketing;
Withdraw consent (Art. 7(3)) — at any time, without affecting the lawfulness of processing carried out before withdrawal;
Lodge a complaint with a supervisory authority (Art. 77) — see section 18.

12. How to exercise your rights

In the application. Your account contains privacy functions that let you:

export your data;
request deletion of your account;
view the history of your consents;
manage your email preferences.

By writing to us at luca.mangiacotti@shellonback.com. We will respond within one month of receipt, extendable by two further months for complex requests, in which case we will tell you within the first month (Art. 12(3) GDPR).

Note on the export function. The export includes your profile and preferences, consent history, saved prompts in full, synchronised sessions, teams, usage metrics (hours, daily presence, daily prompt counts and token totals), activity data (platforms, office avatar, ranking and leaderboard choices), answers to in-app messages and plugin installs. Team chat messages are not included: they are end-to-end encrypted and only your devices can read them. If anything you expected is missing, ask us and we will provide it.

We may need to verify your identity before acting on a request.

13. Security

We apply technical and organisational measures appropriate to the risk, including:

passwords stored only as bcrypt hashes (cost factor 12);
API access secured with tokens;
encryption in transit (TLS) for all connections to our services;
encryption at rest for workspace paths in session records, for the authentication token on the desktop, and for terminal output buffers on the desktop, using the operating system's secure storage;
end-to-end encryption of team chat (section 6.17);
encryption at rest of integration tokens, Google Meet tokens and organisation webhook settings; organisation provisioning (SCIM) tokens stored only as a hash;
systematic scoping of database queries to the owning user, to prevent access to other users' records;
audit logging of administrative actions;
storage of the primary infrastructure in the European Union.

Known gaps that we state rather than conceal, and that are being addressed:

two local configuration files store API keys unencrypted (section 5);
the current desktop application stores saved SSH passwords and keys unencrypted on your device (section 5);
team chat direct messages sent before October 2026 are stored unencrypted (section 6.17);
one workspace table stores the project path unencrypted, while equivalent fields elsewhere are encrypted;
the mobile remote relay is protected by TLS in transit but is not end-to-end encrypted.

Data breach. In the event of a personal data breach we will notify the supervisory authority within 72 hours where required by Art. 33 GDPR, and will inform affected users where Art. 34 requires it. Our internal detection and notification procedure is documented and operational.

14. Cookies and similar technologies

The website promptops.it uses cookies and similar technologies. A banner lets you choose between technical, functional, analytics and profiling categories. Non-essential categories are disabled by default and are activated only after you accept them; Google Consent Mode is initialised with all non-essential consent signals denied.

The applications use local storage on your device for technical purposes — keeping you signed in, storing your preferences, and caching data for offline use. These are not tracking technologies.

Full detail, with each item listed by name, purpose and duration: Cookie Policy.

This approach follows art. 122 of the Italian Privacy Code and the Garante's cookie guidelines of 10 June 2021: no non-essential storage before consent, granular categories, and withdrawal as easy as consent.

15. Children

PromptOps is not intended for children. The minimum age to hold an account is 16, matching the age of digital consent under Italian law.

We do not knowingly collect data from anyone below that age. If you believe a child has provided us with personal data, contact us and we will delete it.

16. Automated decision-making

We do not make decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing within the meaning of Art. 22 GDPR.

Automated processes exist for anti-abuse purposes (for example rate limiting, and throttling of prompt counting to prevent artificial inflation of ranking). These may restrict a function temporarily. If such a measure affects you and you disagree with it, contact us and a person will review it.

The ranking review tool (section 6.11) only flags accounts for a person to examine; it does not suspend anyone. The choice of which in-app messages to show you (section 6.21) uses your usage data but has no legal or similarly significant effects.

17. Changes to this policy

We may update this policy. The version number and effective date at the top always identify the current version.

For material changes we will notify you in advance through the application, by email, or both, and — where the change concerns processing that requires your acceptance — we will ask you to review the new version before continuing to use the service. Previous versions remain available.

18. Contact and complaints

Controller: SHELLONBACK SRL Privacy contact: luca.mangiacotti@shellonback.com Postal address: Via Stupinigi 29, 10092 Beinasco (TO), Italy PEC: shellonback@pec.it DPO: not appointed — see section 2 for the assessment.

Right to complain. If you believe our processing infringes data protection law, you may lodge a complaint with the Italian supervisory authority:

Garante per la protezione dei dati personali Piazza Venezia 11, 00187 Roma, Italy www.garanteprivacy.it

You may also complain to the supervisory authority of your habitual residence or place of work, or bring proceedings before the courts.

19. Version history

Version	Date	Status	Changes
1.0	28 March 2026	Superseded	Initial version
2.0	2 August 2026	Superseded on 1 November 2026	Full rewrite based on verified code behaviour. Adds: local-only data table, honest disclosure of active sub-agent prompt storage, per-activity legal bases, sub-processor list, transfer section, disclosure of known security gaps. Intended to replace all previously published notices.
2.1	1 November 2026	In force from 1 November 2026	Adds: teams, presence and virtual office (6.15); team token leaderboard, for Teams users only and with opt-out (6.16); end-to-end encrypted team chat (6.17); projects, tasks and files (6.18); integrations, plugins and Google Meet (6.19); organisations, SSO and SCIM (6.20); in-app messages and beta programme (6.21); desktop error reports (6.14); on-device voice transcription; ranking details and moderation. Updates: retention now applied automatically, what account deletion removes, contents of the data export, new recipients, and the current state of SSH credential storage.

If you spot something in this document that looks wrong or unclear, write to us — we would rather fix it than defend it.