Privacy Policy

Introduction

Welcome to the Excel SOS Privacy Policy ("we", "our", or "the Service"). This policy describes how we collect, use, store, and protect your personal data when you use excelsos.app and related services.

The Service is subject to the General Data Protection Regulation (GDPR – EU Regulation 2016/679) and applicable Italian and EU data protection law.

Data Controller

The data controller for your personal data is Excel SOS, reachable at: privacy@excelsos.app

Data We Collect

We collect the following categories of personal data:

Account Data

• First and last name
• Email address
• Password (stored in encrypted/hashed form, not readable by us)
• Registration date

Service Usage Data

• Questions and requests submitted to the AI assistant (free text)
• Screenshots and spreadsheet images voluntarily uploaded
• Excel formulas shared for translation or analysis
• Conversation history with the assistant

Technical Data

• IP address
• Browser type and operating system
• Pages visited and time spent
• Session identifiers (technical cookies)

Payment Data

Payment data (credit card details, etc.) is handled directly by our certified payment provider. We do not store full card details.

How We Use Your Data

We use your data for the following purposes:

• Service Delivery: to answer your Excel questions via artificial intelligence
• AI Processing: your questions and uploaded screenshots are sent to third-party AI services to generate responses (see "Third-Party Services" below)
• Account Management: to create and manage your user profile
• Customer Support: to respond to your support requests
• Service Improvement: to analyse usage in aggregate form and improve features
• Service Communications: to send you important notifications about your account or the Service
• Legal Compliance: to fulfil applicable legal obligations

Legal Basis for Processing

We process your data on the following legal bases:

• Contract performance (Art. 6(1)(b) GDPR): to provide the Service you requested
• Consent (Art. 6(1)(a) GDPR): for marketing communications, where you have provided consent
• Legitimate interests (Art. 6(1)(f) GDPR): for Service improvement and IT security
• Legal obligation (Art. 6(1)(c) GDPR): for tax and regulatory compliance

AI Processing

Excel SOS uses AI models to answer your Excel questions. When you submit a question or upload a screenshot:

• The content is transmitted to third-party AI providers (such as OpenAI or equivalent providers) for processing
• Data is used solely to generate the requested response
• We do not use your questions to train AI models without your explicit consent
• Uploaded screenshots are processed and are not permanently retained on AI provider servers

We recommend that you do not include sensitive personal data (e.g. tax codes, IBANs, health data) in uploaded spreadsheets or submitted questions.

Third-Party Services

We rely on trusted third parties to deliver the Service:

All data transfers to third countries (e.g. the USA) are carried out in compliance with GDPR safeguards, including Standard Contractual Clauses (SCCs).

Cookies

We use technically necessary cookies for the Service to function, and analytics cookies to improve the user experience. For full details, see our Cookie Policy.

Data Retention

We retain your personal data for as long as necessary for the purposes described:

• Account data: for the duration of the contractual relationship and for 10 years after account closure (tax obligations)
• Conversation history: for 12 months from the last activity, unless you configure a different setting in your account preferences
• Technical data and logs: for 90 days
• Payment data: according to the payment provider's terms

Your Rights (GDPR)

As a data subject, you have the following rights:

• Right of access (Art. 15): obtain confirmation of processing and a copy of your data
• Right to rectification (Art. 16): correct inaccurate or incomplete data
• Right to erasure (Art. 17): request deletion of your data ("right to be forgotten")
• Right to restriction (Art. 18): restrict processing in certain circumstances
• Right to data portability (Art. 20): receive your data in a structured, machine-readable format
• Right to object (Art. 21): object to processing based on legitimate interests
• Right to withdraw consent: withdraw consent at any time without affecting the lawfulness of prior processing

To exercise your rights, write to privacy@excelsos.app. We will respond within 30 days.

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali – www.garanteprivacy.it).

Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encrypted communications (HTTPS/TLS)
• Secure password hashing
• Data access restricted to authorised personnel
• Continuous monitoring to detect unauthorised access

Minors

The Service is intended for users aged 16 or older. We do not knowingly collect data from minors below this age.

Changes to This Policy

We may update this Privacy Policy periodically. For material changes, we will notify you by email or via a prominent notice in the Service before the changes take effect.

Contact Us

For any questions about this Privacy Policy:

Email: privacy@excelsos.app Website: excelsos.app