Privacy Policy

1. Our two roles

• Controller — for our own customers’ account and billing data, and for visitors to our website. This policy covers that processing.
• Processor — for the documents customers upload and the questions their website visitors ask through a widget. We process that data only on the customer’s instructions, under our Data Processing Agreement. If you used a chat on another company’s website, that company is responsible for your data — please contact them first.

2. What we collect

• Account data: email address and a hashed password; your organisation and plan.
• Billing data: handled by Stripe. We store your Stripe customer and subscription identifiers and plan status, not your card details.
• Customer content: documents and pages you add, the text and search index we build from them, your bot settings.
• Conversations: questions asked in the dashboard, widget or MCP endpoint, the answers and their sources, the website the widget was on, ratings (helpful / not helpful), and clicks on a handoff link. Widget visitors are not asked to sign in and we do not ask for their names.
• Technical data: to rate-limit the widget we store a one-way hash of the visitor’s IP address, salted per bot, kept for a few minutes. Our hosting providers keep standard server logs, which include IP addresses, for security and troubleshooting.

3. Cookies and local storage

The dashboard uses strictly necessary cookies to keep you signed in, and stores your theme choice in your browser. The widget sets no cookies and stores nothing in a visitor’s browser. We use no advertising or analytics trackers, so no consent banner is needed for Grounded itself.

4. Why we use it, and on what basis

• To provide the Service, run your account and bill you — performance of our contract with you.
• To secure the Service, prevent abuse, and fix problems — our legitimate interest in a safe, working product.
• To send service messages (billing, security, changes to terms) — contract and legitimate interest. We do not send marketing email without your consent.
• To keep tax and accounting records — legal obligation.

We do not sell personal data, and we do not use customer content or conversations to train any model.

5. Language models

To answer a question, the relevant passages and the question are sent to a language model through OpenRouter. Every request is restricted to providers that do not retain prompts or outputs and do not train on them (zero data retention). If no such provider is available, the request fails rather than going to one that retains data.

6. Who we share it with

Only the service providers below, which process data on our behalf under contracts that require them to protect it, and authorities where the law compels us.

7. International transfers

We are registered in Hong Kong; our database is in Germany. Some providers are based in, or may access data from, the United States. Where personal data leaves the European Economic Area, we rely on the EU–US Data Privacy Framework where the provider is certified, or on the European Commission’s Standard Contractual Clauses.

8. How long we keep it

• Account and customer content — while your account is active.
• After an account is closed — deleted within 30 days, except billing records we must keep by law (typically up to 10 years).
• Conversations — until the customer deletes the bot or their account, or asks us to delete them.
• Rate-limit hashes — a few minutes.
• Demos we build from a company’s public documentation — deleted after they expire (14 days), at the latest when the next demo is created.

9. Security

Data is encrypted in transit. Each customer’s data is isolated by row-level security in the database, the widget is only served to websites the customer allows, and access to production systems is limited to us and protected by keys. No system is perfectly secure; we will notify affected customers and authorities of a personal data breach as the law requires.

10. Your rights

Depending on where you live, you may have the right to access, correct, delete or export your personal data, to restrict or object to its processing, and to withdraw consent. Write to us at the address below and we will answer within one month. For data we process for one of our customers, we will pass your request to that customer. You may also complain to your local data protection authority — in the EU, the authority where you live; in Hong Kong, the Office of the Privacy Commissioner for Personal Data (pcpd.org.hk).

11. Children

Grounded is a business service and is not directed at children. We do not knowingly collect children’s data.

12. Changes and contact

We will post changes here and update the date above; material changes are announced by email or in the app.

Massive Dynamic Limited, Hong Kong company registration no. 78076051. Unit 1603, 16/F, The L. Plaza, 367–375 Queen’s Road Central, Sheung Wan, Hong Kong. Email: support@mdhk.ltd.