Privacy Policy

Last updated: June 30, 2026

1. Who We Are

Dialogo is an AI workforce platform operated by Dialogo, Italy. Dialogo is the Data Controller for personal data processed through dialogo.chat.

Contact the data controller: privacy@dialogo.chat

2. Data We Collect

Website visitors (dialogo.chat)

IP address and approximate location (via server logs and analytics)
Browser type, device type, and operating system
Pages visited, time on site, referral source (Google Analytics 4, only with your consent)
Contact form data: first name, last name, email address, message content

Platform users (app.dialogo.chat)

Account information: name, email address, password (hashed)
Workflow inputs and outputs, including prompts sent to AI models
Tool usage data and infrastructure audit logs
Payment information (processed by our payment provider: we do not store card details)

Google Workspace data (platform users who connect Google)

When you authorise Dialogo to connect to your Google account, we may access the following data via the Google APIs listed below, strictly to execute the workflows you configure:

Gmail — email headers, message content, and labels, used to trigger workflows and send or draft replies on your behalf.
Google Calendar — event details and availability, used to schedule or update meetings as part of workflow steps.
Google Drive — file metadata and content of files you share with an agent, used to read inputs or write output documents.
Google Docs — document content, used to extract information or create new documents as workflow outputs.
Google Sheets — spreadsheet data, used to read structured inputs (e.g. lead lists) and write results (e.g. enriched records).

We access only the data required by a specific workflow step. We do not store Google Workspace content beyond what is necessary to complete the requested operation. OAuth access tokens are encrypted at rest. You can revoke Google access at any time from myaccount.google.com/permissions or from your Dialogo workspace settings.

Dialogo's use of data received from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.

3. Legal Basis for Processing (GDPR Art. 6)

Processing Activity	Legal Basis	Article
Contact form submissions	Consent	Art. 6(1)(a)
Newsletter communications	Consent	Art. 6(1)(a)
Analytics cookies (GA4)	Consent	Art. 6(1)(a)
Platform service delivery	Contract performance	Art. 6(1)(b)
Security audit logs	Legitimate interest (security)	Art. 6(1)(f)
Compliance with legal obligations	Legal obligation	Art. 6(1)(c)

4. Sub-Processors and Third Parties

We share personal data with the following sub-processors to operate our services. All US-based processors are covered by Standard Contractual Clauses (SCCs) approved by the European Commission under GDPR Art. 46(2)(c).

Sub-Processor	Purpose	Data Transferred	Country
Vercel Inc.	Website hosting	IP addresses, request logs	USA (SCCs)
Supabase Inc.	Database	Emails, form submissions	USA (SCCs)
Google LLC (GA4)	Analytics (with consent)	Anonymised IP, behaviour data	USA (SCCs)
Anthropic PBC	AI model processing	User prompts (platform only)	USA (SCCs)
OpenAI OpCo LLC	AI model processing	User prompts (platform only)	USA (SCCs)
Google DeepMind	AI model processing	User prompts (platform only)	USA (SCCs)
Google LLC (Workspace APIs)	Gmail, Calendar, Drive, Docs, Sheets integration (platform only, with user authorisation)	Email content, calendar events, document and spreadsheet data accessed per workflow	USA (SCCs)

We do not sell your personal data to any third party.

5. International Data Transfers

Some sub-processors listed above are based in the United States. The USA is not deemed to provide an adequate level of data protection under EU law. We ensure appropriate safeguards are in place for all such transfers through Standard Contractual Clauses (SCCs) approved by the European Commission pursuant to GDPR Art. 46(2)(c).

You may request a copy of the relevant SCCs by contacting privacy@dialogo.chat.

6. Data Retention

Data Type	Retention Period
Contact form submissions	24 months
Newsletter subscriptions	Until unsubscribe + 6 months
Analytics data (GA4)	14 months
Platform account data	Duration of account + 30 days after deletion request
Security audit logs	12 months
Google Workspace data (Gmail, Calendar, Drive, Docs, Sheets)	Processed in real time; not stored beyond workflow execution. OAuth tokens retained until you revoke access.

7. Cookies

We use cookies in two categories:

Strictly necessary cookies: required for the site to function. No consent required.
Analytics cookies (GA4): only set after you give explicit consent. Used to understand how visitors use the site. All data is anonymised. No data is sold to third parties.

You can change your cookie preferences at any time using the Cookie Preferences link in the footer, or by clicking Manage Preferences in the consent banner.

8. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights. To exercise any of them, contact us at privacy@dialogo.chat. We will respond within 30 days.

Right of access (Art. 15): You can request a copy of all personal data we hold about you.

Right to rectification (Art. 16): You can ask us to correct inaccurate or incomplete data.

Right to erasure (Art. 17): You can request deletion of your personal data ("right to be forgotten").

Right to restrict processing (Art. 18): You can ask us to limit how we process your data in certain circumstances.

Right to data portability (Art. 20): You can request your data in a structured, machine-readable format.

Right to object (Art. 21): You can object to processing based on legitimate interests at any time.

Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

Right to lodge a complaint: You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) at garanteprivacy.it.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These include encryption in transit (TLS), access controls, and regular security reviews. Despite these measures, no internet transmission is completely secure.

10. AI Transparency (EU AI Act Art. 50)

Dialogo uses large language models: including Claude (Anthropic), GPT (OpenAI), and Gemini (Google DeepMind): to power its platform. When you interact with Dialogo's AI agents, you are interacting with an automated system, not a human. AI-generated outputs may not always be accurate and should be verified before use in business decisions.

11. Changes to This Policy

We may update this policy to reflect changes in our practices or applicable law. We will post the updated policy on this page with a revised "Last updated" date. For material changes, we will notify registered users by email.

12. Google API Services — Limited Use Disclosure

Dialogo's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

We use Google user data only to provide or improve the features visible to users within the Dialogo platform.
We do not use Google user data to serve advertising.
We do not allow humans to read Google user data unless you have given explicit permission, it is necessary for security purposes (e.g., investigating abuse), or we are required to do so by law.
We do not transfer Google user data to third parties, except as necessary to provide the service, comply with applicable law, or with your explicit consent.

13. Contact

For any privacy-related questions or to exercise your rights:

Email: privacy@dialogo.chat