Personal data processing policy

Operator and contacts for data-transfer questions

Personal data operator: Mikhail Sholokhov, son of Andrei, Private Entrepreneur (Republic of Armenia).

Address: 81/1 Manushyan str., Arabkir, Yerevan 0012, Republic of Armenia.

TIN 20241649, state registration number 286.1574050.

Website: https://airchat.app. Support: https://airchat.app/support.

For all questions about processing or transferring personal data — including access, correction, blocking, or deletion — email hello@airchat.app. This is the Operator’s primary contact for personal data.

1. General

This Policy is prepared in line with the Law of the Republic of Armenia “On Protection of Personal Data” and other applicable rules.

The Operator publishes this Policy at airchat.app/privacy. Using AirChat, the widget, the amoCRM integration, or submitting a form in a client’s chat means you have read this Policy.

Personal data means any information relating to an identified or identifiable individual. Processing means any operation on such data, including collection, storage, use, transfer, and deletion.

2. Data subjects and data we process

We process data of AirChat workspace users, website-widget visitors on client sites, people who message through connected messengers, and users of the AirChat amoCRM widget — only as needed to run the service.

• Account: name, email, password hash, organization membership, and billing details needed for payment.
• Project and channel settings: website widget, WhatsApp, Telegram, Max, and other connected sources.
• Conversation content and attachments sent through AirChat.
• Widget leads: name, phone, email, and other fields the visitor submits.
• Data sent to amoCRM on the client’s instructions: contact, deal, notes, UTM, and related card fields.
• Technical data: IP address, session/device identifiers, app version, cookies, error logs — to operate and secure the service.

3. Purposes and legal bases

We process data to provide AirChat: inbox, widget, AI replies, analytics, support, billing, CRM integration, and delivery to channels the client connects.

Bases: performing the license/offer with the client; the data subject’s consent (including widget forms and sign-up); the Operator’s legitimate interests in security and reliability where this does not override the subject’s rights; and legal requirements.

We do not process special-category or biometric data as a product goal. If such information appears in a message the user sends, it is processed only as part of providing the service.

4. Sharing

We do not sell personal data. We share data with third parties only to run AirChat, on the client’s instructions, or where the law requires it.

• amoCRM (Kommo): if the client connects the integration, lead/contact/deal/conversation data is sent to their amoCRM account under amoCRM’s terms and on the client’s instructions.
• Messengers the client connects (WhatsApp, Telegram, Max, etc.) under those providers’ terms.
• Infrastructure: hosting, file storage, email delivery, payments — only as needed to provide the service.
• LLM and related APIs — to generate replies and product features; the provider receives the request text needed to perform the function.

5. Cross-border transfers

Some infrastructure and LLM providers may be located outside Armenia. Such transfers are made as needed to perform the contract and the features the client uses.

By using AirChat and connecting channels or amoCRM, the client understands that some data may be processed in other countries. Questions about those transfers: hello@airchat.app.

6. Retention and rights

We keep data while the account or project is active and thereafter as required by law, disputes, security, or accounting. We then delete or anonymize it unless the law requires otherwise.

You may request information about processing, correction, blocking or deletion, withdraw consent where processing is based on consent, and lodge a complaint. Email hello@airchat.app. We respond within the time limits of 152-FZ.

7. Security

The Operator applies organizational and technical measures proportionate to risk: limited access, accounts and permissions, encrypted transport, logging, backups, server protection, and software updates.

The client is responsible for passwords, integration keys (including amoCRM), and for lawfully collecting visitor data on their own website (notice, consent, policy link).

8. Cookies and logs

The site and widget may use cookies for session, language, security, and basic product analytics. Blocking cookies may limit dashboard features.

Technical logs (IP, User-Agent, errors) are used for diagnostics and security and are not sold.

9. Instagram data (Meta Platform)

When a client connects an Instagram professional account (Instagram Login, Meta Platforms), AirChat receives, with the account owner's permission: the account's ID and username, an access token, incoming Direct messages and comments on the account's posts, and the IDs and usernames of Instagram users who message the account.

We use this data only to provide the service to that client: showing conversations in the Inbox, AI-assistant replies based on the client's own knowledge base, replies from the client's operators, and automations the client sets up. Instagram data is not sold, not used for advertising, and not shared with third parties other than processors needed to run the service (hosting, AI models).

To disconnect, use Channels → Instagram → Disconnect in the dashboard — the token and connection data are deleted immediately. You can also remove AirChat in Instagram: Settings → Apps and websites. Data deletion instructions: https://airchat.app/data-deletion. To delete conversation history, email hello@airchat.app.

10. Changes

The current version is always at https://airchat.app/privacy. Material changes are reflected in the update date on this page. Continued use after publication means you accept the updated Policy unless the law requires otherwise.