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Privacy Policy

Effective November 5, 2026

This policy explains what personal data OrbScale collects, why, who processes it for us, where, and how long we keep it. It covers our website, the OrbScale dashboard and the chat window (the “widget”) that our customers put on their own websites. OrbScale is run by one person, Duong Nguyen Anh Khoa, trading as OrbScale, based in Ho Chi Minh City, Vietnam (“we”).

A Member is someone with an OrbScale account. A Visitor is someone who chats with an Orb on a Member's website.

Our role

What we collect

From Members

From Visitors

Cookies and browser storage

Why we use it, and our legal basis

We don't sell personal data, we don't send marketing email, and we don't use your content or Visitors' messages to train AI models. The model providers we use don't train on it either under their terms for paid API use.

Who processes data for us

Your files and Knowledge Base are stored on a server we rent from netcup, in Germany. Splitting and indexing them runs on that server too, and sends your text to no one else. These companies (subprocessors) process data for us, each only for the purpose listed and under their own data-protection terms:

We will update this list before we add a subprocessor that handles Visitor or customer content.

International transfers

Several of these companies process data outside the EU and the UK, mainly in the United States. Where the law requires it, we rely on the safeguards they offer, such as the European Commission's standard contractual clauses, and we carry out the transfer assessments the law requires.

How long we keep it

Security

No system is perfectly secure. If a breach affects your data, we will tell you, and the authorities where required, without undue delay.

Your rights

Depending on where you live, including under the EU and UK GDPR and Vietnam's personal data protection law, you can ask to access, correct, delete or receive a copy of your personal data, to restrict or object to how we use it, and to withdraw consent you gave. You can also complain to your data-protection authority; in Vietnam, that is the Department of Cybersecurity and High-Tech Crime Prevention (A05) of the Ministry of Public Security.

Vietnam

We follow Vietnam's personal data protection rules, including Decree 13/2023/ND-CP. This policy is our notice of how we process personal data under those rules, including its transfer abroad to the subprocessors listed above. Where they require a Visitor's consent, the Member's business collects it.

Children

OrbScale is for businesses and is not meant for anyone under 18. Members must not aim their Orbs at children. If you think a child's data has reached us, write to [email protected] and we will delete it.

Changes

If we change this policy in a way that matters, we will email Members before the change takes effect. The date at the top shows when this version took effect.

Contact

Privacy questions and requests: [email protected]. We are Duong Nguyen Anh Khoa, trading as OrbScale, Ho Chi Minh City, Vietnam. Our full postal address is available on request at [email protected].