Privacy Policy
This policy is issued by LanaChat legal entity name, address, registration number, a Wyoming (USA) limited liability company ("LanaChat", "we", "us"). Privacy questions and data requests: [email protected]. Data protection contact: [email protected].
1. Who this policy is for
This policy explains what personal data LanaChat handles, why, and what rights people have. It concerns four groups of people:
- Visitors of lanachat.ai, including people who use the support chat widget or book a call;
- Team members of an agency: the owner, managers and chatters who sign in to the console at app.lanachat.ai, use the API or the MCP server;
- Creators whose Telegram accounts an agency connects to the Service;
- Fans who chat with those Telegram accounts and buy content there.
It should be read with the Terms of Service, the Cookie Policy and, for agencies, the Data Processing Addendum.
2. Our role: controller or processor
- We are the controller for the personal data of visitors, of team members (account and sign-in data, billing, support history, usage of the console) and of the people who contact us. We decide why and how that data is processed.
- We are a processor for the personal data of Fans and Creators that flows through the Service: Telegram identifiers, names, messages, media, purchases, notes, tags and tracking data. The agency is the controller of that data. It decides which accounts to connect, what Lana may say, what is stored and for how long, and it answers Fans' and Creators' requests. We process that data only on the agency's documented instructions, as set out in the Data Processing Addendum.
- Telegram, payment providers (Telegram Stars, FanGate, Dropp Fans or others the agency uses) and the agency's other tools are separate controllers with their own privacy policies.
3. What data we collect
3.1 Visitors of lanachat.ai
- Technical data sent by the browser when a page loads: IP address, user agent, requested page, referrer, time. Kept in server logs.
- Language choice, stored in the browser only (see the Cookie Policy).
- Support widget: the email address and the messages a visitor types, plus a guest thread token stored in the browser so the conversation can continue.
- Call booking: name, email, Telegram handle if given, chosen slot and the notes typed in the form.
- Google Fonts: the landing loads a font from Google's servers; Google receives the IP address of the browser for that request. No cookie is set by this request.
3.2 Team members of an agency
- Account data: name, email, role, workspace, sign-in method, password hash or passkey, two-factor settings, session identifiers.
- Activity in the console: pages opened, conversations read, messages sent, takeovers, settings changed, API and MCP calls, with timestamps and IP address. This audit trail lets the agency see who did what.
- Billing: top-ups, wallet addresses or payment references, licences bought, shares deducted, invoices and tax identifiers.
- Support and communications: emails, chat threads and feedback.
3.3 Creators (processed for the agency)
- Telegram account and bot identifiers, display name, handle, phone number used for connection, bot tokens (stored encrypted).
- The persona: name, age statement, tone, story, boundaries, prices and scripts the agency writes.
- Vault media: photos, videos and voice notes the agency uploads, stored encrypted, with the descriptions the agency writes for Lana.
- Age and consent records are held by the agency, not by us; we only ask to see them when section 3 of the Terms requires it.
3.4 Fans (processed for the agency)
- Telegram user identifier, display name, handle, language and the profile data Telegram exposes to the account.
- Every message exchanged with the connected account, in text, voice or media, whether written by the Fan, by Lana or by a team member, with timestamps.
- Purchases: what was bought, when, for how many Stars or through which payment link, refunds and reversals.
- Notes, tags, lists (for example excluded or VIP) and the tracking link through which the Fan arrived.
- Signals Lana derives to run the conversation: spending level, preferences, last activity, and flags such as a suspected minor or a complaint.
We do not ask for, and the agency must not store in the Service, government ID numbers, payment card numbers, health data or any data about minors.
4. Where the data comes from
From the people themselves (forms, sign-in, messages typed), from the agency (accounts it connects, media and settings it uploads, team it invites), from Telegram through its official interfaces when an account is connected, from payment providers when a sale is confirmed, and from our systems (logs, derived signals, generated replies).
5. Why we process data and on what legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Provide the Service to the agency: run Lana, deliver media, record sales, show the console | Team, Creator and Fan data | Performance of the contract with the agency (Art. 6(1)(b)) for team data; the agency's instructions under the DPA for Creator and Fan data |
| Create and secure accounts, sessions, keys and two-factor | Team data, logs | Contract; legitimate interest in security (Art. 6(1)(f)) |
| Bill licences and shares, refund unused balance, keep accounting records | Billing data | Contract; legal obligation (Art. 6(1)(c)) |
| Answer support requests and book calls | Visitor and team contact data, messages | Steps before a contract; legitimate interest in answering people who write to us |
| Keep the Service safe: detect abuse, spam, fraud, minors, security incidents | Logs, conversations, flags | Legitimate interest; legal obligation where reporting is required |
| Improve the Service: measure performance, fix bugs, tune Lana for the agency's own workspace | Usage data, the agency's own conversations and sales | Legitimate interest; contract (the tuning is part of the Service) |
| Send product news to workspace owners | Legitimate interest for existing customers, with an unsubscribe link in every email; consent elsewhere | |
| Comply with the law, respond to authorities, defend claims | Any relevant data | Legal obligation; legitimate interest |
Where we rely on legitimate interest, we have checked that the interest is not overridden by the rights of the people concerned; details are available on request.
6. AI processing
- Lana generates replies with large language models operated by third-party AI providers. To generate a reply, the relevant parts of a conversation, the persona, the scripts and the media descriptions are sent to the provider. The provider returns the text and does not keep it beyond what is needed to deliver the request and to meet its own abuse and legal obligations.
- Our contracts with AI providers prohibit them from using this data to train or improve their models. We only use providers that offer this commitment in writing.
- LanaChat does not train models that serve other customers on Fan or Creator data. We may tune Lana's behaviour for one agency using that agency's own data; that tuning serves only that agency and is deleted with its workspace.
- Decisions with legal or similarly significant effects on a person are never made by Lana alone. Lana's safety rules can stop a conversation (for example on suspicion that a Fan is a minor); a team member can review and override that decision in the console.
- The agency decides whether and how Fans are told that an AI takes part in the conversation, and must do so where the law or Telegram requires it.
7. Who receives the data
We share personal data only with the people and companies below, each bound by contract to use it only for the purpose we define.
- The agency and its team, through the console, the API and the MCP server, within the roles the agency sets.
- Telegram, to send and receive messages and Stars on the connected accounts; Telegram processes that data under its own policy.
- Payment providers chosen by the agency (Telegram Stars, FanGate, Dropp Fans or others): they receive what is needed to confirm a sale.
- Sub-processors, by category: cloud hosting and storage; database and backups; AI model providers; transactional email; error and performance monitoring; support chat infrastructure; payment and crypto on-ramp providers for top-ups. The current list with names and locations is available to agencies on request at [email protected] and is kept as described in the DPA.
- Authorities, where the law requires it, or where we must report child sexual abuse material or imminent harm.
- A successor in case of merger, acquisition or sale of the business, under the same commitments.
We never sell personal data and do not share it with advertisers or data brokers.
8. International transfers
Our hosting, AI providers and other sub-processors may be located outside the country of the person concerned, including in the United States. Where data of people in the European Economic Area, the United Kingdom or Switzerland is transferred to a country without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses (and the UK Addendum where relevant), together with the additional measures described in section 9. Copies of the clauses can be requested at [email protected].
9. Security
- Data is encrypted in transit (TLS) and at rest. Vault media, bot tokens and API keys are encrypted with keys separate from the database, and tokens are never shown again after they are saved.
- Access is limited by workspace and by role: a team member only sees the creators and screens the agency allows. Our own staff access production data only when needed to operate the Service or to answer a support request, and such access is logged.
- Rate limits, anomaly detection and Telegram limit handling protect accounts from abuse and from being flagged.
- Backups are encrypted, stored separately and tested for restore.
- We notify the agency of a personal data breach affecting its data without undue delay and within 48 hours of confirming it, with the information the agency needs to meet its own obligations.
- No system is perfectly secure. Team members must use strong, unique passwords, keep two-factor enabled and report any suspected compromise at once.
10. How long we keep data
| Data | Retention |
|---|---|
| Server logs of lanachat.ai | 30 days |
| Support widget and booking data | 24 months after the last message, or until deletion is requested |
| Team member accounts and activity log | Life of the workspace, then deleted 30 days after termination; the activity log is kept 12 months for security and billing (LanaChat is the controller of this log, see section 2) |
| Billing records and invoices | As long as the tax and accounting laws of our country require (typically 10 years) |
| Creator and Fan data (conversations, purchases, media, notes) | As long as the agency keeps the account connected or until it deletes it in the console; 30 days after termination of the workspace for export, then deleted, with encrypted backups rolling off within 90 days |
| Abuse reports and safety flags | 5 years, or as long as needed to meet a legal obligation |
11. Rights of Fans and Creators, and how an agency handles them
Fans and Creators in the EEA, the UK, California and other places with similar laws have the right to access their data, to correct it, to delete it, to restrict or object to its processing, to receive a copy in a portable format, and to complain to a supervisory authority. Because the agency is the controller:
- A Fan or Creator should first contact the agency, usually by writing to the Telegram account they chat with or to the agency's own contact point.
- If a request reaches LanaChat directly, we forward it to the agency within 5 working days and help it respond, as described in the DPA. We only answer directly where the law requires us to, or where the agency no longer exists.
- The console lets the agency export or delete a Fan's conversation and profile, and disconnect a Creator's account, so it can act on a request without our involvement.
12. Rights of team members and visitors
Team members and visitors have the same rights over the data we hold as controller. Write to [email protected] from the address linked to the account; we may ask for proof of identity, and we answer within one month (extendable by two months for complex requests, with notice). Team members can also update their profile and sign-in settings in the console. If an agency removes a team member, the member's account is closed and the data retained only as described in section 10. Anyone can lodge a complaint with the data protection authority of their country of residence; for the EEA the list is at edpb.europa.eu.
13. Cookies and similar technologies
The Cookie Policy lists every cookie and browser storage key we use and how to control them. In short: strictly necessary items only (session on the console, language and support thread on the website), no advertising cookies, no third-party analytics.
14. Minors
The Service is for adults only. We do not knowingly collect data from anyone under 18, and the agency must not connect an account of, or chat with, a minor. If we learn that data of a minor is in the Service, we block the Fan or account, delete the data as soon as the law allows (after preserving what must be kept for a report), and inform the agency. Anyone who believes a minor is involved should write to [email protected] immediately.
15. California and other US state residents
This section applies to residents of California under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and, where they grant similar rights, to residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and other states with comprehensive privacy laws.
- We do not sell or share personal information. LanaChat has not sold personal information in the preceding 12 months, does not share it for cross-context behavioural advertising, and does not use or disclose sensitive personal information for purposes other than providing the Service. There is no "Do Not Sell or Share My Personal Information" link because there is nothing to opt out of.
- Categories collected in the preceding 12 months, as listed in section 3: identifiers (name, email, Telegram identifiers, IP address); commercial information (purchases, top-ups); internet activity (console use, server logs); audio and visual information (voice notes and media in conversations); inferences (spending level, preferences); sensitive personal information (account credentials; the content of messages, which may reveal sex life or sexual orientation). Sources and purposes are in sections 4 and 5. Disclosures for a business purpose go to the service providers of section 7 only.
- Your rights: to know what personal information we collect, use and disclose; to access it; to delete it; to correct it; to limit the use of sensitive personal information; and not to be discriminated against for exercising these rights. Exercise them at [email protected]; we verify the request against the account's email and answer within 45 days (extendable once by 45 days with notice). An authorised agent may act for you with written permission.
- Service provider. For Fan and Creator data, LanaChat is a service provider (CCPA) or processor of the agency and processes that data only for the business purposes of the Terms and the Data Processing Addendum. Requests from Fans and Creators are handled as in section 11.
- Retention and metrics. Retention periods are in section 10. As a business-to-business service in private beta, we do not currently publish request metrics; they are available on request.
16. Changes to this policy
We update this policy when the Service, our sub-processors or the law change. The date at the top shows the current version. Material changes are announced in the console or by email to workspace owners at least 30 days before they take effect, unless a change is required immediately by law.
17. Contact
LanaChat legal entity name, address, registration number
Email: [email protected]
Data protection contact: [email protected]