1. Controller
The controller of personal data is Konrad Bejger, a sole trader operating under the business name “Konrad Bejger”, entered in the Polish Central Register and Information on Economic Activity (CEIDG), ul. Magellana 6/64, 80-288 Gdańsk, Poland, tax ID (NIP) 8781795948, REGON 367501781 (“Footler”, “we”).
For anything about personal data, write to [DO UZUPEŁNIENIA: e-mail kontaktowy] or by post to the address above.
We have not appointed a Data Protection Officer (DPO) because we are not required to. We handle all data protection matters directly.
2. Who this policy covers
- people who visit the website and use the chat, the signature review and the test e-mail;
- customers and people who create an account or act on behalf of a customer company;
- people who write to our e-mail address, including in reply to our message;
- people whose companies we send a message about e-mail signatures (outreach);
- recipients of our customers’ e-mails who display a signature or open an online contact card.
We process the employee data that a customer company enters into its dashboard on that company’s behalf – see section 5.
3. Data, purposes and legal bases
The legal bases are those of Article 6(1) GDPR: (a) consent; (b) a contract or steps taken at your request before entering into it; (c) a legal obligation; (f) our legitimate interest.
Website and chat with signature proposals
Data: the website address you give; data read from that website (company name, colours, logo, address, phone, e-mail, social media links); the content of your chat messages, including your name, job title, phone and e-mail if you type them in.
Purpose: preparing signature proposals. Basis: Article 6(1)(b) GDPR; data of other people read from a public company website – point (f) (providing the service you ask for).
We do not store the conversation on the server. We only store the downloaded logo as a working file. Messages and website data are passed to an AI model (section 6).
Signature screenshot review
Data: an image of your current signature (usually name, job title, phone, e-mail, logo, sometimes a photo) and your notes. Purpose: reviewing the signature and proposing better ones. Basis: point (b). We do not store the image – after the AI model reviews it, it is gone from the server’s memory.
Test e-mail (“Send it to myself”)
Data: e-mail address and signature data. Purpose: sending the signature to your address and creating a dashboard with it. Basis: point (b).
Account, dashboard and subscription
Data: e-mail address, password (we only store its hash), session identifier (also stored as a hash), language, company and signature data in the dashboard, trial dates, chosen plan, number of seats, payment status, date the signature installation was confirmed, invoicing data.
Purpose: creating and running the account, providing the service, the trial and reminders before it ends, billing. Basis: point (b); issuing invoices and keeping accounting records – point (c) (tax and accounting law). We do not process payment card data – the payment provider does (section 7).
Messages to us and the e-mail assistant
E-mails sent to our address are answered by our e-mail assistant. Data: e-mail address, name, message content, technical headers (including the mail server and program and the result of the sender’s SPF/DKIM/DMARC check), attachments and images, and the data in your signature: job title, company, phone numbers, e-mail addresses, website, address, social media profiles, logo and photo if they are in the signature; your own rating of your signature if you give one.
Purpose: replying to the message, rating the signature, preparing proposals and your proposals page (behind a random link that cannot be guessed), matching the installation guide to your e-mail program, protection against abuse (limits, skipping automatic replies). Basis: point (b) (we answer your request) and point (f) (handling correspondence, keeping the service secure).
Messages about signatures to businesses (outreach)
We may send a short message to a company’s business e-mail address asking how it rates its signature. Data: business e-mail address, first name (if we know it), company name, language, correspondence history, whether you opted out. Source: publicly available company data, e.g. websites.
Purpose: direct marketing of our services to businesses. Basis: point (f) – our legitimate interest. You can object to such messages at any time – just reply “STOP”. After you object we do not write to you again; we only keep the address and the fact that you objected, so that we can respect it (point (f)).
Signature images and online contact cards
A signature in an e-mail is an image loaded from our server, and clicking it opens an online contact card. When a recipient displays the signature or opens the card, their e-mail program or browser connects to our server and technically sends its IP address and browser details. We do not record who displayed a signature or when, and we do not track e-mail opens. We only count the total number of card opens, which the customer sees in the dashboard. Basis: point (f) (operating and securing the service).
The contact card and the signature image are available to anyone who has the link – just like any signature in an e-mail that has been sent.
Company-wide rollout request
Data: e-mail address, mail platform (Google Workspace, Microsoft 365, Apple), team size, phone and notes if you give them. Purpose: getting in touch and preparing the rollout. Basis: point (b).
Contacting us
Data: data in the correspondence. Purpose: replying. Basis: point (f), and point (b) where the matter concerns a contract.
News with your consent
If you consent, we may send you news about Footler. Basis: point (a). You can withdraw consent at any time; withdrawal does not affect the lawfulness of processing before it.
Visit statistics and tests of page versions
We count visits to the home page and steps in the service (e.g. clicking a button, starting the chat, getting proposals, keeping a signature) with our own tool, without third-party scripts. Without your consent – without cookies and without storing anything in your browser: we recognise a visitor only within one day, by a short hash of the IP address, browser information and a random key that we change every day, deleting the previous one. We do not store the IP address or the browser information, and the hash cannot be linked to the address or to the same browser on another day.
If you consent to statistics cookies in the consent banner, we store the cookie footler_visitor with a visitor identifier in your browser for 13 months, so we recognise you on later visits and keep showing you the same version of a page in a test. The identifier is the hash we recognised you by that day (or a random number), so it holds none of your data, and from the next day on it cannot be linked to the IP address. Our server uses it only while your consent still holds; once you withdraw it, we delete the cookie and go back to the daily hash.
Data: that daily hash or – after consent – the identifier from the cookie, the date and time, the page language, where the visit came from (the campaign tag in the link, or only the name of the site it came from, e.g. a search engine), an approximate country (from the browser’s language settings, e.g. “pl-PL” → Poland, or from the country given by a content delivery network if the site runs through one) and the page version when we compare two versions (an A/B test). The steps of people who received our message and of customers (e.g. the e-mail delivered, the link clicked, the account created, the payment) are recorded with an internal identifier – without the e-mail address, name, IP address or browser information.
Purpose: knowing how people use the service and which version of a page works better; only we see the statistics. Basis: point (f) (our legitimate interest in improving the service); the identifier from the cookie – point (a) (your consent, which the Polish Electronic Communications Law also requires for storing and reading the cookie).
Cookie consent banner (Cookiebot)
On the home page and the legal documents’ pages we ask for consent to cookies that are not strictly necessary. The banner is provided by Cookiebot (section 7). Data: the IP address and browser information (to show the banner that fits your country and language – Cookiebot does not keep them at that point), and once you choose an option: your choice, the date and time, the page address, browser information, a shortened IP address and a random consent identifier, which also goes into the CookieConsent cookie in your browser. Purpose: collecting consent, remembering the choice and being able to show that you consented. Basis: point (c) in conjunction with Article 7(1) GDPR (the obligation to demonstrate consent).
Security and legal claims
Protecting the service against abuse (e.g. limits on requests from one IP address – we keep the address only in the server’s memory for the duration of the limit), establishing, pursuing and defending legal claims. Basis: point (f).
4. Where the data comes from
- directly from you – forms, the chat, the dashboard and correspondence;
- from public company websites – when you give the address or it follows from your signature or the domain of your e-mail address;
- from e-mails you send us, including the signature and attached images;
- from your employer or principal, if they added you to their dashboard (section 5);
- from publicly available sources of company data (outreach).
5. Employee data in customers’ dashboards
A company that uses Footler enters data of its employees and collaborators into the dashboard: name, job title, phone, e-mail, LinkedIn profile, photo and company data. That company is the controller of this data, and we process it on its behalf under a data processing agreement (Article 28 GDPR) – template: Data Processing Agreement. If your data is in a company’s dashboard, please exercise your rights primarily with that company – we will help it fulfil them.
6. Artificial intelligence and automated decisions
Some features use the Claude AI model by Anthropic: the chat, the screenshot review, reading and rating a signature from an e-mail, detecting the language and topic of a message, the e-mail assistant’s replies and designing custom signature designs. The model receives only the data needed for the task at hand.
The 0–10 signature score is calculated automatically: our software awards points for signature elements (e.g. logo, phone), and the AI model rates only the look. We also classify messages automatically (e.g. whether they are about signatures) so that the assistant does not reply to spam or abuse. These assessments concern the signature and the message, not you, and they have no legal effect on you and do not similarly significantly affect you – we make no decisions within the meaning of Article 22 GDPR.
We do not use photos to recognise or identify people, so we do not process them as biometric data. If you disagree with a score or the assistant’s reply, write to the address in section 1 – a human will answer.
7. Recipients
We entrust data only to providers that help us run the service, under contracts and their terms of service:
- Anthropic (Anthropic Ireland, Limited, Ireland, and Anthropic, PBC, USA) – the Claude AI model (section 6);
- Resend (Plus Five Five, Inc., USA) – sending and receiving e-mails;
- Railway (a US company; the Service’s servers are in the EU, in the Netherlands) – hosting provider: servers, database and files;
- payment provider – Stripe Payments Europe, Limited (Ireland), once payments are live; for some purposes, such as fraud prevention and anti-money-laundering, Stripe processes data as an independent controller;
- Google (Google Ireland Limited, Ireland) – signing in to your Google account when you install your signature with the “Install in Gmail” button; Google processes your Google account data as an independent controller, under its own privacy policy;
- Usercentrics (Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark) – the cookie consent banner and consent log Cookiebot; we use its European servers (consent.cookiebot.eu), so the data does not leave the European Union.
Data also reaches providers of our accounting and legal services and competent authorities where the law requires it. The service’s pages load nothing from other companies – fonts and scripts come from our own server. The exceptions are the Cookiebot consent banner on the home page and the legal documents’ pages (consent.cookiebot.eu) and the “Install in Gmail” step: when it is available, the page loads Google’s sign-in script (accounts.google.com).
The data you put in your signature and contact card is visible to every recipient of your e-mails and to anyone with the link to the card.
8. Transfers outside the EEA
Resend and Railway are based in the USA, and Anthropic, Stripe and Google also process data in the USA, so data may be processed outside the European Economic Area. Transfers are made with the safeguards of Chapter V GDPR:
- Anthropic – standard contractual clauses (SCCs) approved by the European Commission (Decision (EU) 2021/914), Modules 2 and 3, incorporated into Anthropic’s data processing addendum;
- Resend – standard contractual clauses (SCCs), Modules 2 and 3, under Resend’s data processing addendum; Plus Five Five, Inc. also participates in the EU-US Data Privacy Framework;
- Railway – the EU-US Data Privacy Framework (Commission Decision (EU) 2023/1795; Railway Corporation holds an active certification) and, beyond its scope, standard contractual clauses (SCCs) under Railway’s data processing addendum;
- Stripe – the EU-US Data Privacy Framework (Stripe, LLC holds an active certification) and, beyond its scope, standard contractual clauses (SCCs) under Stripe’s Data Transfers Addendum;
- Google – the EU-US Data Privacy Framework (Google LLC holds an active certification) and, where needed, standard contractual clauses (SCCs).
You can obtain a copy of the safeguards by writing to the address in section 1.
9. How long we keep data
- account and dashboard – for the term of the contract, then until claims become time-barred (generally 3 years, counted to the end of the calendar year); an account whose trial ended without a payment – 6 months from the end of the trial (we send a reminder 14 days before); after the deletion only the size and language of each signature image stay at its address – no personal data – so that sent e-mails show a narrow Footler strip instead of a broken image;
- accounting documents such as invoices – 5 years from the end of the calendar year in which the tax payment deadline passed;
- an account not confirmed through the e-mail link – 24 hours, after which we delete it together with its dashboard;
- login session – until you log out, at most 30 days;
- correspondence, signature rating and proposals page without an account – 12 months from the last contact;
- a dashboard created by the test e-mail, without an account – 7 days from its creation;
- a logo downloaded in the chat (working file) – 30 days;
- addresses that replied “STOP” – as long as needed to respect the objection (only the address and date);
- data processed on the basis of consent – until consent is withdrawn;
- statistics of visits and steps in the service – 12 months, after which only daily counts without identifiers remain; the key of the visitor’s daily hash – until the end of the day; the cookie with the visitor identifier (
footler_visitor) – 13 months from consent or until you withdraw it; - your choice in the consent banner – in your browser (the
CookieConsentcookie) 12 months, in Cookiebot’s consent log 12 months from when you gave it; - technical server logs – up to 30 days.
After these periods we delete or anonymise the data. Employee data in customers’ dashboards is deleted under the data processing agreement.
10. Your rights
- access to your data and a copy of it (Article 15 GDPR);
- rectification (Article 16);
- erasure (Article 17);
- restriction of processing (Article 18);
- data portability (Article 20) – where we process the data by automated means on the basis of a contract or consent;
- objection (Article 21) – to processing based on our legitimate interest; an objection to direct marketing always ends such processing;
- withdrawal of consent at any time (Article 7(3));
- a complaint to the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl).
To exercise your rights, write to [DO UZUPEŁNIENIA: e-mail kontaktowy]. We will reply without undue delay and at the latest within one month; in exceptional cases this may be extended by two further months, in which case we will let you know.
11. Do you have to give us data
Giving data is voluntary, but without some of it we cannot provide the service – for example, you cannot create an account without an e-mail address. Invoicing data is a statutory requirement.
12. Cookies
We use strictly necessary cookies: the login session (footler_session), the chosen language (lang) and the remembered choice in the consent banner (CookieConsent). Only with your consent – the statistics cookie footler_visitor; without consent, visit statistics are counted without cookies (section 3). We do not use advertising cookies. Details and changing your consent: Cookie Policy.
13. Security
We use encrypted connections (HTTPS), store passwords only as hashes (scrypt), use random links that cannot be guessed for dashboards, contact cards and proposals pages, limit the number of requests, block access to private network addresses when fetching websites and give access to data only to people who need it.
14. Changes to this policy
We may change this policy, e.g. when we add a feature or a new provider. The current version is always on this page, with its version number and date. We will tell customers about significant changes by e-mail.
15. Contact
Konrad Bejger, ul. Magellana 6/64, 80-288 Gdańsk, Poland · e-mail: [DO UZUPEŁNIENIA: e-mail kontaktowy]