Privacy Policy

This policy explains how ТОВ «АПРИКОД» (APRICODE LLC, “Apricode”, “we”, “us”) handles personal data in APROS, our business operating system, and on this website, apros.app. It covers the APROS web app at <company>.apros.app, the APROS mobile and desktop apps where they are used, the checkout at buy.apros.app, and the integration service at auth.apros.app.

Summary

• Each customer company gets its own APROS workspace, with its own application instance and database, hosted by Hetzner in Germany.
• The company that uses APROS controls the data in its workspace. We process that data on its behalf. For our own customer accounts, billing, website and support, we are the controller.
• AI features send data to AI providers. AI Brain is part of every workspace; other AI features depend on the plan. What they send can include conversations from Facebook Messenger, Instagram and WhatsApp, emails and calendar events. Our main AI provider is Microsoft (Azure AI Foundry). The AI processing section explains when this happens.
• We do not sell personal data, do not use it for advertising, and do not train AI models on it.
• To have data deleted, follow our Data Deletion Instructions or email hello@apri-code.com.

Who we are

APROS is developed and operated by:

• ТОВ «АПРИКОД» (APRICODE LLC), EDRPOU code 41644485
• 9 Rustaveli St., Kharkiv 61001, Ukraine
• Email: hello@apri-code.com

We use one address for privacy, support and security. Emails are read by Apricode’s management and team, and we handle privacy requests by hand.

Our two roles

We hold personal data in two different roles.

We are the controller (under Ukrainian law, the “owner of personal data”) of:

• data about visitors to this website, and the details people give when they join our waitlist;
• the details given when buying a plan, and the account and billing data of our customers;
• emails and other messages you send us;
• crash reports and diagnostic data from the app, apart from the Customer Data they can contain (see Crash reports and diagnostics);
• data we need to run and secure the service: usage statistics, AI usage records without content, and the integration service’s records.

We are a processor (under Ukrainian law, a “manager of personal data”) of everything a customer company puts into its workspace or receives into it through the channels and services it connects: customers, leads, contacts, deals, messages, emails, calendar events, files, calls, invoices and so on. We call this Customer Data. The customer company is its controller and decides why and how it is processed. Our Data Processing Addendum sets out our duties as processor.

If you are a customer, employee or contact of a company that uses APROS, that company is responsible for your data. Please contact it first. We will help it answer you, and you can always write to us.

Data we collect as controller

Visitors to this website

apros.app sets no cookies of its own, runs no analytics and loads nothing from other companies. If you use its theme switch, your choice of theme is kept in your browser’s local storage and is never sent to us. Cloudflare delivers the site and processes your IP address and browser details to do so and to protect the site from attacks. See the Cookie Policy.

Waitlist

Buying APROS through this website is not open yet. Instead, you can join our waitlist with the form on apros.app.

• Who is responsible: Apricode, as controller.
• What we collect: your work email address (required); your name, company, team size and the plan you are interested in; an optional message; the time you gave your consent; the page you signed up from and any campaign tags in its address (utm_ values); and a salted SHA-256 hash of your IP address. We do not store your IP address itself. The hash is used only to prevent abuse of the form, such as repeated automated sign-ups.
• Why: to contact you about APROS becoming available to you and about getting started.
• Legal basis: your consent. You can withdraw it at any time by emailing hello@apri-code.com; we then delete your sign-up.
• Where it is stored: in a Cloudflare D1 database (Cloudflare, Inc.), on Cloudflare’s network, with the primary database location in Western Europe.
• How long: until you become a customer or ask us to delete it. If you do not become a customer, we delete it at the latest 12 months after APROS opens for sign-ups.
• What we do not do: we do not sell or share the list, do not add you to anyone else’s marketing list, and do not track you on the website.

Buying a plan

Buying plans through the website is not open yet; we currently onboard customers directly and send them an invoice. When you buy a plan, either directly from us or at our online checkout at buy.apros.app once it is open, you give:

• your company name and the workspace address you choose;
• the full name, email address, phone number (optional) and password of the workspace’s first administrator.

We use these details to create your workspace and the administrator’s account, to bill you and to contact you about the service. The online checkout passes through Cloudflare’s network.

If you pay by card at the online checkout, you pay on monobank’s payment page. monobank (JSC Universal Bank) processes the payment as a bank under its own rules. We receive the result of the payment, such as its status and amount, but not your full card details. If you pay an invoice by bank transfer, we receive the payment details that your bank sends with the transfer.

Your account with us and support

We keep the account owner’s contact details, the plan, payments and invoices. When you write to us, we keep your messages and our replies so that we can help you and follow up.

Crash reports and diagnostics

APROS sends us automatic crash reports. When the app hits an error in your browser, it sends us:

• the error message and technical trace;
• the page address, including its query string;
• your browser type, screen size and language, and the workspace name;
• the last 20 errors and warnings from the browser console, and the last 10 failed network requests with their addresses;
• the last 15 things you clicked, each labelled with up to 80 characters of its text.

Administrators can also send us a bug report by hand. Such a report also includes their user id and role, and an automatic screenshot of the page they are on, which can show any data on that page.

A report can contain text that was on the page. A click is labelled with the text of what was clicked. Clicking an email in the mail list can therefore put its sender, subject and first words into the report, and clicking a conversation can put the contact’s name into it, including the name of someone who wrote through Messenger, Instagram or WhatsApp. Console messages and request addresses can contain other workspace data. That text is Customer Data: we process it on behalf of the workspace, only to find and fix the fault.

Each report is first structured by the workspace’s AI model (see AI processing) and then sent to our control plane at cp.apros.app. We delete crash and bug reports when the fault is fixed, and at the latest 12 months after we receive them.

Automatic reports are on by default, and there is no setting for them in the app yet. They can be switched off only for a single browser, by setting the local-storage value apros.autoBugReport to off. Write to us if you need help with this.

We do not use any third-party analytics, tracking or error-reporting service in APROS.

Running and securing the service

• Usage. For plan limits and billing, each workspace reports aggregate figures to our control plane: the number of users, the storage used and the number of files. These reports contain no content.
• AI usage. For each AI request, the workspace records the feature, model, number of tokens, cost, duration and result, without the content. This lets us apply each workspace’s AI spending limit.
• Integration service (auth.apros.app). This service connects Google and Meta accounts to workspaces, routes messages that Meta sends to the right workspace, and issues short-lived access tokens for real-time features, video calls and documents. It stores which Telegram chat, Facebook Page or WhatsApp number belongs to which workspace, and protected (hashed) credentials for each workspace. It does not store message content and does not keep Google or Meta access tokens; those are handed to the workspace, which stores them encrypted. Like any web server, it keeps access logs of the requests it receives.

Customer Data we process for our customers

What a workspace holds depends on how the customer uses APROS. It can include:

• people and companies: names, email addresses, phone numbers, job titles, companies, notes, deals, tasks and activity history;
• conversations from the channels the workspace connects: Facebook Messenger, Instagram, WhatsApp, Telegram, Viber and the website chat widget;
• email and calendars from connected mailboxes and calendars;
• calls: video and phone call recordings and transcripts;
• documents and files, such as invoices, quotes and contracts;
• finance: payments and imported bank transactions, including counterparty names;
• users of the workspace: their accounts, roles, departments, positions, phone numbers and sign-in sessions (IP address, browser, device and last activity);
• AI data: questions asked of AI Brain and agents, their answers, and the memories agents keep in the workspace.

We process Customer Data only to provide APROS to the customer as it configures and uses it, as described in our Data Processing Addendum.

Some features process Customer Data automatically unless the workspace switches them off:

• Leads from conversations and email. A new conversation from a messaging channel can create a lead, and so can mail from a new sender in a connected mailbox. Both are on by default and can be switched off in the chat and mailbox settings.
• Staff notifications. When a customer’s message arrives, staff get a notification with the sender’s name and the first 100 characters of the message. When a lead is created from an email, the notification can carry the sender’s name or email address. By default, notifications appear in the app and are sent by email. Staff can also choose to receive them in Telegram, where the full text is sent, or as mobile push notifications, where the message text is hidden.
• Which mailbox sends the workspace’s own email. Email that APROS sends for the workspace rather than for a particular person, such as notification emails, booking confirmations and video-call invitations, is sent from the workspace’s shared mailbox. If the workspace has no shared mailbox, it is sent from the first mailbox connected to the workspace, which can be an employee’s own Gmail or other mailbox; copies then appear in that mailbox’s sent mail. If no mailbox is connected and the backup is enabled, notification emails go through our backup email provider (Resend).

Data from Meta platforms

This section explains what APROS does with data it receives from Facebook Messenger, Instagram and WhatsApp, which are provided by Meta Platforms. Meta’s Platform Terms call this “Platform Data”.

How the integration works

A business that uses APROS can connect its Facebook Page, its Instagram professional account and, where available, its WhatsApp Business number to its workspace. From then on, messages people send to that Page, account or number arrive in the business’s APROS workspace, and its team, or an AI agent the business sets up, replies from APROS.

APROS acts as a technology provider for that business. We process Platform Data only on the business’s behalf and at its direction, never for our own purposes or for another business, and we keep each business’s data in its own workspace, separate from all others.

Permissions we request

When a business connects Meta accounts, APROS asks for these permissions:

What data we receive

About people who message the business:

• the identifier Meta assigns to the person for that Page, account or number, and the identifiers of their messages;
• their name (on Instagram, their name or username) and profile photo, which APROS looks up from Meta;
• on WhatsApp, their phone number and the profile name they set in WhatsApp;
• the text of their messages, and the photos, files and other attachments they send;
• other message events that Meta sends.

APROS saves a copy of the profile photo and of attachments in the business’s workspace storage, because the links Meta provides expire.

If a business connects a WhatsApp number that it keeps using in the WhatsApp Business app at the same time, WhatsApp may also share the number’s existing contacts and recent chat history. APROS imports that history as conversations, without creating leads from it, and copies into the conversation the messages the business sends from the WhatsApp Business app.

About the business that connects: the identifiers and names of the connected Pages, accounts and numbers, and the access tokens Meta issues for them and for the person who connected them. Tokens are stored encrypted.

How we use it

We use Platform Data only to provide the business’s own messaging in APROS:

• to connect the Pages, accounts and numbers the business chose;
• to receive messages and deliver the replies the business sends;
• to show the business who it is talking to, with name and profile photo;
• to keep the conversation history, linked to the matching contact or lead (and, unless the business switches it off, to create a lead for a new conversation);
• to notify the business’s staff of new messages, as described in Customer Data;
• to run the AI features described below, where the business uses them.

AI processing of Meta conversations

Conversations from Messenger, Instagram and WhatsApp are processed by AI features in the same way as conversations from any other channel. APROS does not exclude them. The AI requests go through our AI gateway to Microsoft (Azure AI Foundry), as described in AI processing.

• Smart replies. In a workspace with the AI module switched on, when a member of the business’s staff opens or updates a conversation, APROS automatically sends the last 30 messages of the conversation to the AI model, with the names of the people writing, the contact’s name and email, and details of the related lead, deal and company. The model suggests three replies. They are only suggestions: a person decides whether to send one. Smart replies are on by default; each staff member can switch them off in the chat toolbar for their browser.
• Summaries. When a staff member asks for a summary, up to the last 200 messages are sent to the AI model.
• Translation. When a staff member turns translation on for a conversation, each message is sent to the AI model to be translated as it is displayed. Staff can also ask AI to correct, translate or rephrase their own draft replies.
• AI agents that reply. A business can attach an AI agent to a channel. In its default mode, the agent replies to people automatically, without a person approving each reply. It reads the last 20 messages of the conversation and the CRM data its tools allow, and its reply is sent to the person through Messenger, Instagram or WhatsApp. If a business uses such an agent, the replies you receive from that business may be written by AI. APROS itself does not currently add a notice telling you that a reply was written by AI.
• Lead enrichment. If the business switches it on (it is off by default), the last 30 messages can be sent to the AI model to fill in details of the related lead.
• Search index. When the business rebuilds its knowledge index, the contact’s name, the channel, the last message and tags of each conversation are turned into a search index by an embedding model that we run on our own servers, unless the business chooses a different model.
• Automations. A business can build automations that pass conversation data to an AI step.

The business decides whether to use these features. Businesses that let AI reply to people must tell them so where the law or Meta’s rules require it (see our Acceptable Use Policy).

What we do not do with Platform Data

• We do not sell, license or rent it.
• We do not use it for advertising, and we do not give it to data brokers or advertising platforms.
• We do not use it for surveillance, or to decide anyone’s eligibility for housing, employment, insurance, education or credit.
• We do not combine it across businesses or build profiles of people outside the business’s own workspace.
• We do not use it to train AI models.

Where it is stored and who can see it

Platform Data is stored in the business’s workspace database and file storage on our servers in Germany. Meta sends messages to our integration service, which checks Meta’s signature and passes each message to the right workspace without storing its content.

It can be seen by:

• the users of the business’s workspace, within the permissions the business gives them;
• the AI providers that process it when AI features run (see AI processing);
• Apricode staff who maintain APROS, only as far as their work requires: support, fixing faults and carrying out deletion requests.

Names and short previews of messages can also appear in staff notifications, including notification emails and Telegram messages, and in crash reports, as described in Customer Data and Crash reports and diagnostics.

How long we keep it and how to delete it

Platform Data stays in the business’s workspace as conversation history until it is deleted.

• When a business disconnects Meta in APROS, new messages stop arriving and the connection’s user access token is deleted. The conversation history stays, and so do the encrypted access tokens of the disconnected Page, account or number, marked inactive. Both stay until they are deleted on request.
• If a business removes APROS in its Meta settings instead, Meta stops giving APROS access, but APROS is not told: the channels still look connected in APROS, and the stored tokens and history stay until they are deleted.
• People who messaged a business, and businesses that connected Meta accounts, can ask us to delete this data. The Data Deletion Instructions explain how.
• When a business’s APROS account is closed (see How long we keep data), we delete the Platform Data in its workspace within 30 days.

Requests from public authorities

We check every request for data from a public authority to make sure it is lawful, challenge requests that are not, disclose only the minimum necessary and record every request. In the 12 months before 17 October 2026, we did not disclose any data received from Meta platforms to a public authority.

Google user data

This section explains how APROS accesses, uses, stores, shares and deletes data it receives from Google APIs.

What APROS uses Google for

A user of an APROS workspace can connect their Gmail mailbox and their Google Calendar, so that they can read and send email and keep their calendar in APROS next to their customers, deals and tasks. APROS does not offer “Sign in with Google” and does not use any other Google API.

What APROS asks for and why

How APROS uses Google user data

APROS uses Google user data only to provide features you can see and use in APROS:

• to show your mail and calendar in APROS, and to send the mail and write the events described in the table above;
• to link messages and events to the right contacts, leads and deals. Unless you switch it off in the mailbox settings, mail from a new sender creates a lead, and staff can be notified of it with the sender’s name or email address;
• if you publish a booking page, to show visitors which times are free: your busy times, including synced Google events, are taken into account, but event details are not shown;
• to let you search your mail;
• to run AI features on your mail and events when they are used, as described next.

AI features and Google user data

• AI Brain and AI agents can read synced mail and calendar events when you ask them to, or when an AI agent or automation that your workspace set up runs. An automation set up by your workspace’s administrators can run an AI step on your mail without asking you each time, for example whenever an email arrives. The AI tools read only mailboxes and calendars that the acting user is allowed to access. A mail tool reads up to 50 messages of a thread, with each message body cut to 4,000 characters. The content is sent through our AI gateway to Microsoft (Azure AI Foundry) to produce the answer or action.
• Search index. When the workspace rebuilds its knowledge index, the subject, sender name, sender address and preview of each email are turned into a search index by an embedding model that we run on our own servers, unless the workspace chooses a different model.
• APROS treats mail received from Gmail in the same way as mail from any other mailbox.

We do not use data obtained through Google Workspace APIs, or anything derived from it (including the search index), to develop, improve or train generalized or non-personalized AI or machine-learning models. APROS contains no code that trains or fine-tunes AI models.

Limited Use

APROS’s use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

In particular:

• we use Google user data only to provide and improve the user-facing features described above;
• we transfer it to others only as this section describes: to Microsoft, our AI provider, when an AI feature processes it; to Hetzner, which hosts our servers; as names, email addresses or short previews in staff notifications (in the app, by email, in Telegram, or as push notifications through Expo) and in crash reports; and otherwise only for security purposes, to comply with the law, or as part of a merger, acquisition or sale of assets after obtaining your explicit prior consent;
• we never transfer or sell it to advertising platforms, data brokers or information resellers, never use it to serve ads, and never use it to determine creditworthiness or for lending;
• Apricode staff do not read your Gmail messages or calendar events unless you have agreed to it for specific messages or events (for example, to solve a support request), it is necessary for security purposes, such as investigating a bug or abuse, it is necessary to comply with the law, or the data has been aggregated and anonymised for internal operations. Note that a crash report can contain the sender, subject and first words of an email you clicked (see Crash reports and diagnostics).

Inside your workspace, who else can see your mailbox and calendar is decided by your workspace’s roles and permissions.

Storage and protection

• Synced mail and events are stored in your workspace’s own database, and attachments in your workspace’s file storage, on our servers in Germany.
• Google access and refresh tokens are stored in your workspace encrypted with AES-256-GCM, together with the permissions you granted. Our integration service exchanges tokens with Google but does not store them.
• Connections to APROS use HTTPS. The Security page describes our other safeguards.

Revoking access and deleting Google user data

• Removing a mailbox or calendar in APROS stops syncing, but it does not revoke APROS’s access at Google. The encrypted token stays stored in your workspace. Removing a mailbox deletes its synced messages from the workspace database, but not their attachment files, their search-index entries or leads created from the mail. Removing a calendar connection keeps the events already copied into your APROS calendar.
• To revoke APROS’s access, remove APROS in your Google Account at myaccount.google.com/linkedapps, or write to us and we will revoke it at Google and delete the stored token.
• To delete what was copied, ask your workspace administrator or follow our Data Deletion Instructions. We delete the remaining copies, including attachment files, calendar events, search-index entries and audit-log copies, within 30 days of a verified request.

AI processing

This section applies to every AI feature in APROS.

Which features use AI

• In every workspace, on every plan: AI Brain (the assistant on the home screen, including voice input) and knowledge search.
• Where the plan includes the AI module: AI agents and automations built in AI Studio; AI in conversations (smart replies, summaries, translation, writing help, channel agents and lead enrichment); and call AI (the live call coach, transcription and post-call analysis).
• Also: work-day summaries generated for each employee when their work day starts and ends, AI insights in analytics, document and image generation, and structuring of crash reports.

Where the data goes

• AI gateway. AI requests from the APROS web app go through an AI gateway that we run on our own servers, with a separate key and spending limit for each workspace.
• Microsoft. From the gateway, requests for text generation, speech-to-text (including transcription of voice notes and phone-call recordings) and image generation go to models hosted by Microsoft in Azure AI Foundry, including OpenAI models hosted by Microsoft.
• Search index. By default, the embedding model that turns text into a search index runs on our own servers. If a workspace chooses an embedding model hosted by a provider, the indexed text goes to that provider.
• Backup model. Where our gateway is configured with a backup model, a request can go to OpenAI’s own service when Microsoft’s is unavailable.
• Call coach. When the AI call coach joins a video call, it sends the audio to Deepgram, and the transcript together with CRM details it looks up to OpenAI, directly (see Calls, recordings and transcription).
• Web research. When an AI agent reads a web page, the page address goes to Jina AI. When it searches the web, its query goes to Serper or, with the workspace’s own key, to Jina AI. Agents write these queries themselves, and they can include names of people or companies.

An AI request carries the content the feature works on: for example, the messages of a conversation, an email thread, a document, CRM records the agent reads, or a recording.

Training and provider retention

• We do not use Customer Data to train AI models, and APROS contains no code that trains or fine-tunes models. “Learning” features in APROS, such as agent memory and feedback, store notes and settings in the workspace’s own database. They do not change any AI model.
• AI providers process the data under their own terms. Those terms may allow them to keep inputs and outputs for a limited time, for example to detect abuse. We do not promise that a provider keeps nothing.
• Deepgram runs a model improvement programme. APROS does not currently ask Deepgram to exclude call-coach audio from it, so Deepgram’s terms for that programme apply to that audio.

AI that acts

APROS AI agents work within the permissions their workspace gives them. Each agent has an autonomy level. At the most autonomous level, an agent can take actions, including sending messages and email, without a person approving them; deletions by APROS AI agents always need a person’s approval. An AI agent attached to a messaging channel replies to customers automatically in its default mode. Changes that APROS AI agents make are recorded with the agent run that made them. AI clients that you connect to APROS over MCP (such as ChatGPT, Claude or Cursor) act with the permissions you grant them, which can include deleting data.

Calls, recordings and transcription

• Video calls run on our own media server. Audio and video are encrypted in transit between each participant and the server.
• Defaults. New workspaces start with call recording, the AI call coach (which joins calls automatically) and automatic post-call AI analysis switched on. Administrators can switch recording and the coach off in the call settings.
• What guests see. People who join a call through an invitation link do not currently see an indicator in APROS that the call is being recorded or that the AI coach is listening. Staff of the workspace do see these indicators.
• Recordings are stored in the workspace’s file storage.
• Live call coach. When the coach joins a video call, the audio of every participant is streamed to Deepgram for live transcription. The transcript, together with any CRM details of the contact, lead, deal or company that the coach looks up, is sent to an OpenAI model, which gives the business’s staff live hints.
• Phone calls. Recordings that a workspace’s phone system passes to APROS are transcribed through our AI gateway by Microsoft’s speech-to-text model.
• Analysis. Post-call analysis of transcripts runs through our AI gateway.
• Retention. Call recordings are deleted automatically once they are older than the retention period in the call settings: 90 days in a new workspace, which an administrator can change. Transcripts stay until they are deleted.

The business that holds the call is responsible for telling participants and getting their consent where the law requires it.

Other services that receive data

Besides the AI providers above, a few services receive personal data when certain features are used:

• Push notifications to mobile apps go through Expo, which passes them to Apple or Google. The notification title can contain a person’s name; the text of chat messages and comments is hidden.
• Staff notification emails, booking confirmations and video-call invitations are sent from a mailbox connected to the workspace, as described in Customer Data. If no mailbox is connected and the backup is enabled, notification emails go through Resend.
• Payment pages of a workspace that accepts card payments through Stripe, and the Telegram Mini App, load those companies’ scripts.
• The Meta connection page loads Meta’s JavaScript SDK, and the Meta settings page in APROS shows Page pictures loaded from Meta.
• Images inside emails. When you open an email in APROS, images it links to load from the sender’s servers. This can tell the sender that the email was opened, and from which IP address.
• Country-flag images in the app load from react-circle-flags.pages.dev, a site that the author of an open-source library runs on Cloudflare Pages. It receives the viewer’s IP address. We have no contract with its operator.
• Google Fonts load on the Meta connection pages and in AI-generated proposal presentations and other AI-generated HTML designs, so Google receives the viewer’s IP address.

The full list, with what each company receives, is on our Sub-processors page.

Cookies

This website sets no cookies of its own. APROS workspaces use three strictly necessary cookies: two keep you signed in and one remembers your language. None of them is used for analytics or advertising. Details are in the Cookie Policy.

Legal bases

Where the GDPR applies, we rely on these legal bases for the data we control. Under the Law of Ukraine “On Personal Data Protection”, the equivalent grounds are contract, legal obligation, legitimate interest and consent.

For Customer Data, the customer company decides the legal basis as controller.

You must give the details needed to create a workspace and to pay; without them, we cannot provide APROS. We do not make decisions that have legal or similarly significant effects on you based only on automated processing.

Sharing and disclosure

We share personal data only:

• with the companies that help us provide APROS, listed on our Sub-processors page. We have written contracts with them, except those that page lists as having none;
• with monobank, to take card payments for your plan;
• with the services a workspace chooses to connect, when the workspace uses them;
• with public authorities, when the law requires it, as described in Requests from public authorities;
• with a buyer or successor if Apricode or APROS is sold or merged, under the same protections, after telling you (and, for Google user data, after obtaining your explicit consent).

We do not sell personal data and do not share it for advertising.

How long we keep data

• Customer Data stays in the workspace for as long as the workspace exists, unless the customer deletes it. APROS does not delete Customer Data automatically after a set time, with three exceptions: call recordings are deleted once they are older than the retention period in the call settings (90 days in a new workspace); an AI agent can be set to forget memories it has not used for a set time; and some short-lived technical records are cleared.
• Deleted items. When a contact, lead, deal, company or task is deleted, a full copy stays in the workspace’s audit log. Deleting a conversation does not remove its files from storage. A deleted chat message is hidden, but its text stays in the database. Some items, such as those deleted by AI agents, can be restored by an administrator. We remove these copies when the customer or the person concerned asks us to (see Data Deletion Instructions).
• Sign-in sessions (IP address, browser and device) and the audit log stay in the workspace database until they are deleted.
• When a subscription ends, we keep the workspace for 90 days after the end of the last paid period, so that the customer can renew or take a copy of its data. At least 30 days before those 90 days run out, we email the account owner. When they run out, we close the account and delete the workspace and its data, including data received from Meta platforms, within 30 days. A customer can also ask us to delete its workspace sooner; we do so within 30 days of a verified request.
• Waitlist sign-ups are kept until you become a customer or ask us to delete them, and at the latest until 12 months after APROS opens for sign-ups (see Waitlist).
• Account and billing records are kept while you are our customer and afterwards for as long as Ukrainian accounting and tax law requires.
• Support emails are kept for 3 years after our last contact with you, the general limitation period under Ukrainian law.
• Crash and bug reports are deleted when the fault is fixed, and at the latest 12 months after we receive them.
• System logs of our servers can contain identifiers, names and email addresses. We do not yet publish how long they are kept.

International transfers

• APROS data is stored on servers in Germany, rented from Hetzner.
• Apricode is based in Ukraine, and our staff access data from Ukraine to run, support and fix the service. Ukraine does not have an adequacy decision from the European Commission. For Customer Data subject to the GDPR, we use the European Commission’s Standard Contractual Clauses, as set out in our Data Processing Addendum.
• Some providers process data outside the European Economic Area: Microsoft (the Azure region we use may be outside the EEA), Deepgram and OpenAI in the United States, and others listed on our Sub-processors page. Where we have a data-processing contract with the provider, we rely on the Standard Contractual Clauses or an adequacy decision, including the EU-US Data Privacy Framework where the provider is certified under it. The Sub-processors page lists the providers with which we have no such contract; for them, no such safeguard is in place.
• You can ask us for a copy of the safeguards we use by writing to hello@apri-code.com.

Security

We protect personal data with measures that include: a separate application instance and database for each workspace; HTTPS for connections to APROS from browsers and apps; encryption with AES-256-GCM of most stored credentials, such as access tokens, passwords for connected mailboxes and API keys of AI providers; passwords stored only as bcrypt hashes; role-based permissions; and an audit log. Other data, including messages and emails, is not encrypted at the application level and is protected by access controls. APROS does not offer two-factor authentication yet. The Security page describes our measures in detail and how to report a vulnerability.

Your rights

Depending on the law that applies to you, including the GDPR and the Law of Ukraine “On Personal Data Protection”, you have the right to:

• know whether we hold data about you, where it comes from, where it is, why we process it and who receives it, and get a copy of it;
• have inaccurate data corrected;
• have data deleted;
• restrict or object to processing, including processing based on our legitimate interests;
• receive data you gave us in a machine-readable format and have it sent to another provider;
• withdraw consent at any time, where we rely on it;
• know how automated processing works and not be subject to decisions based only on automated processing that have legal effects on you;
• complain to a supervisory authority.

To use these rights, email hello@apri-code.com. We may ask you to confirm your identity, but we will never ask for passwords, access tokens or copies of identity documents. We tell you within 10 working days whether and when we will act on your request, and answer it fully within 30 days.

If your request concerns Customer Data, we pass it to the company that controls the data and help it answer you. For data APROS received through Meta platforms or Google APIs, we can also act on your deletion request ourselves, as described in the Data Deletion Instructions.

Complaints. In Ukraine, you can complain to the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua) or to a court. In the European Union, you can complain to the data protection authority of the country where you live or work, or where you believe the law was broken. We would be grateful for the chance to resolve your concern first.

Children

APROS is a service for businesses and is not directed at children. Users of APROS must be at least 18. People of any age may message a business that uses APROS; in that case, the business is responsible for that data. If you believe we hold data about a child by mistake, write to us and we will delete it.

Changes to this policy

We may update this policy when APROS or the law changes. The current version is always on this page, with its effective date and the date of the last update at the top. If a change materially affects how we use data we already hold, we will tell customers by email before it takes effect and, where the law requires, ask for consent.

Language versions

This document is published in Ukrainian and English, and both versions have the same content. If they differ, the Ukrainian version prevails. This does not limit any right you have under the law that applies to you.

Contact

ТОВ «АПРИКОД» (APRICODE LLC), EDRPOU code 41644485, 9 Rustaveli St., Kharkiv 61001, Ukraine. Email: hello@apri-code.com.