Who we are
Tolkly is operated by Evgenii Zakharov (Անհատ ձեռնարկատեր Եվգենի Զախարով Սերգեյի), an individual entrepreneur registered in the Republic of Armenia under state registration number 286.1480564, taxpayer identification number 40325938, 97 Buzand St., apt. 17, Kentron district, Yerevan 0002, Republic of Armenia. Write about your data to support@tolkly.io.
We decide how data about the people who sign in to the app is used. Data about the visitors of a customer's site is processed on that customer's behalf: the customer decides why it is collected, and a visitor's request about it goes to the customer first.
What we process and why
| Whose | What | Why | Basis |
|---|---|---|---|
| People who sign in to the app | Email, name, Google or Telegram account id, sign-in times, devices and IP address | To let you in, keep your account safe and limit abuse | The contract; our legitimate interest in security |
| The person who creates a company | The same, and the time and version of the terms they accepted | To provide the Service under the Terms | The contract |
| Members of a company | Their role, work name shown to visitors, shifts, replies | To run the company's inbox | The contract with the company |
| Visitors of our customers' sites | Messages, contacts they leave, files, the page, country and time zone, an identifier the site may send, a keyed hash (HMAC) of the IP address, never the address itself; the Telegram id, name, username and language of a visitor who writes through the customer's own Telegram bot | To answer them on the customer's behalf, hand them to its people and block spam | The customer's instructions |
| Visitors of tolkly.io | Pages visited, without cookies, in Rybbit | To know which pages are read | Our legitimate interest |
We do not sell personal data and do not use it to train models.
Who else receives it
| Who | Country | What for |
|---|---|---|
| Hetzner Online GmbH | Finland | Servers and the database |
| Cloudflare, Inc. | USA, worldwide network; files in the EU | Delivery of the site and the widget, protection, embeddings of messages and pages, file storage (R2, EU) |
| Anthropic, PBC | USA | The AI model answering visitors in the countries and industries its terms allow |
| DeepSeek | China | The AI model answering the other visitors and checking answers when the main checker fails |
| TypeSafe AI, Inc. | USA | Checking that an answer rests on its sources, and whether a message needs a person |
| Plus Five Five, Inc. (Resend) | USA | Sign-in codes and service emails |
| Telegram | UAE | Handed-off conversations in the company's Telegram group, visitors writing through the customer's Telegram bot, sign-in with Telegram |
| Google LLC | USA | Sign-in with Google |
| Polar Software, Inc. | USA | Card payments, as merchant of record |
| FD Transfers LLC (NowPayments) | Saint Vincent and the Grenadines | Crypto payments |
| Rybbit | EU | Statistics of tolkly.io, never inside the app |
Which model answers a visitor is chosen per message, so that every provider serves only the audience its terms allow. Anthropic's model answers only when the site's industry is stated and allowed by Anthropic's terms, the visitor's country is known and on Anthropic's supported list, and the device's time zone is not Russia's or Belarus's. Otherwise DeepSeek answers, as it does every message through a customer's Telegram bot, where the country is not known; a conversation that went to DeepSeek stays there.
Where the data is kept
The database is on servers in Finland (Hetzner). Files (visitors' files, pictures of people and of the AI, logos and uploaded knowledge files) are kept in Cloudflare R2 in the EU. The providers above process data in their own countries, outside the Republic of Armenia; we use them under their data processing terms.
How long it is kept
Account data is kept while the account exists. Conversations and the knowledge of a company are kept while the company exists; a deleted project is removed for good 30 days after deletion. Files sent in a conversation are removed after 30 days. The keyed hash of a visitor's IP address is kept with the conversation.
Your rights
You may ask what data we hold about you, ask us to correct or delete it, or object to its use, by writing to support@tolkly.io; we answer within 30 days. A visitor of a customer's site writes to that customer, and we help the customer answer. You may also complain to the data protection authority where you live.
Changes
We publish each new version here with its date and tell the owners of companies about a material change by email.