Last updated: 23 September 2026
1. Who we are
Sofia AI S.r.l. ("we", "us"), Via Torino 21, 20123 Milano, Italy, is the data controller for the Sofia AI service (the "Service"). Privacy questions: privacy@sofia-ai.example.
2. Data we process
2.1 Account data (you, the customer)
- Name, email address, password (hashed), billing details and invoices.
- Telegram connection data: phone number, Telegram user ID, username, and an MTProto session file (created by the MadelineProto client) that lets the Service read and answer incoming private messages on your behalf.
- Persona configuration: system prompts and their version history, photos you upload with their descriptions, sign-up links, runtime settings.
- Usage and technical data: IP address, browser, pages visited, actions in the admin panel (activity log), error logs.
2.2 Conversation data (people who message your Telegram account)
- Telegram peer ID, username and first name of the sender.
- Message text, timestamps, photos sent by the persona, and the AI-generated "memory" summary of the conversation (facts the sender shared, preferences, tone).
- Free-message counters and which sign-up link was offered.
You are responsible for informing the people you chat with, where required, that replies are automated. We act as a processor for conversation data on your instructions; you remain the controller for it.
3. Why we process it and on what legal basis
| Purpose | Legal basis (GDPR art. 6) |
|---|---|
| Providing the Service: connecting Telegram, generating replies, sending photos, follow-ups, memory | Contract (art. 6(1)(b)) |
| Billing, invoices, accounting | Contract and legal obligation (art. 6(1)(b), (c)) |
| Security, abuse prevention, rate limiting, activity logs | Legitimate interest (art. 6(1)(f)) |
| Product analytics on aggregated usage | Legitimate interest (art. 6(1)(f)) |
| Marketing emails to customers | Consent or legitimate interest, with opt-out (art. 6(1)(a), (f)) |
4. AI processing and sub-processors
To generate replies, the relevant part of a conversation (recent messages, the memory summary and your persona prompt) is sent to a large language model through OpenRouter, Inc. (USA), which routes it to the model you selected. Your Telegram session, phone number and payment data are never sent to AI providers. Photos are stored on our servers and sent to Telegram only when the persona attaches them.
Other sub-processors: hosting and object storage (EU data centres), Telegram (MTProto API, for message delivery), email delivery provider, Stripe Payments Europe, Ltd. (payments and invoicing; card details are entered on Stripe and never reach our servers), error monitoring. A current list is available on request.
Transfers outside the EEA rely on the EU Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework.
5. Retention
- Account data: for the life of the account and 30 days after deletion, then erased (invoices kept 10 years for tax law).
- Telegram session: destroyed immediately when you disconnect the account or delete your account.
- Conversations, memories and photos: for the life of your account; you can delete any conversation at any time from the admin panel.
- Activity and security logs: 12 months.
- Contact form messages: 24 months.
6. Security
Telegram session files are stored on our servers with restricted file-system access and are destroyed as soon as you disconnect the account; two-factor passwords you enter during login are encrypted. Passwords are hashed with bcrypt, all traffic uses TLS, admin actions are logged, and access to production is restricted to named staff with two-factor authentication. No system is perfectly secure; report vulnerabilities to privacy@sofia-ai.example.
7. Your rights
Under the GDPR you may request access, rectification, erasure, restriction, portability, and object to processing based on legitimate interest, and withdraw consent at any time. Write to privacy@sofia-ai.example; we answer within 30 days. You can also lodge a complaint with your supervisory authority (in Italy, the Garante per la protezione dei dati personali).
If you are a person who chatted with a customer's Telegram account and want your messages deleted, contact us with the account's username and we will forward and enforce the request with the customer.
8. Children
The Service is for adults only. We do not knowingly process data of anyone under 18; accounts found to be used with minors are terminated.
9. Cookies
See our Cookie Policy.
10. Changes
We will notify customers by email of material changes at least 14 days before they take effect. The "last updated" date at the top reflects the current version.