Privacy Policy for Personal Data Processing

This Privacy Policy is prepared in accordance with the Law on Personal Data Protection of the Republic of Serbia (RS Official Gazette No. 87/2018) and describes how Individual Entrepreneur Milana Mikhailovna Fedotova, registered under the laws of the Republic of Serbia (hereinafter: “Operator”, “Controller”, “we”), processes personal data of users of the website https://grailgun.ai (hereinafter: “Website”, “Service”). By using the Service, the User (“you”) agrees to this Privacy Policy.

1. Data Controller

The Controller of your personal data is:

Milana Mikhailovna Fedotova, Entrepreneur registered in the Republic of Serbia

Email: info@grailgun.ai

Address: Tikveška 19, Voždovac, Belgrade, 11050

2. Categories of Personal Data We Collect

We collect only the data necessary to provide and ensure the functioning of the Service.

2.1. Data obtained through messenger authorization We support Telegram, WhatsApp, Viber and other messengers. From them we may receive:

• messenger username;
• display name;
• messenger user ID (unique numeric identifier);
• profile photo (if the messenger provides it);
• interface language (for example, ru, en);
• message content processed by bots solely for forwarding, automation or filtering.

2.2. Technical data

• IP address;
• browser and device information;
• log files;
• cookies and similar technologies.

2.3. Payment-related data Processed by third-party providers:

• card token (we do not store full card numbers);
• transaction identifiers;
• subscription status;
• payment history.

We do not store or process full card details. All sensitive payment data is processed by certified payment processors.

3. Purposes and Legal Bases of Processing

We process personal data for the following purposes:

• to provide access to the Service and its core functionality;
• to ensure messenger authorization and bot operation;
• to maintain and improve the Website and Service;
• to process payments and manage subscriptions;
• to provide customer support and reply to requests;
• to ensure Service security and prevent fraud;
• to comply with legal obligations, including accounting and tax laws.

The legal bases for processing include performing a contract, fulfilling legal obligations, legitimate interest, and, when necessary, your consent.

4. How We Use Messenger Data

We process messenger data exclusively for providing Service functionality.

We do not analyze message content for advertising purposes, do not sell it, and do not transfer it to third parties except as necessary to operate the Service or comply with the law.

5. How We Process Personal Data

Processing activities include collection, recording, storing, updating, restricting, deleting, depersonalizing, and otherwise handling personal data required for Service functionality.

We do not conduct automated decision-making that produces legal or similar significant effects on the user.

6. Sharing of Personal Data

We may share your data with:

• payment processors;
• hosting and infrastructure providers;
• analytics and technical support services;
• messenger platforms and integrations;
• government bodies when required by Serbian law.

We never sell your data or share it for marketing purposes.

7. Cross-Border Transfers

Because the Service interacts with international messenger platforms, your personal data may be transferred outside the Republic of Serbia.

We use legal safeguards for such transfers, including Standard Contractual Clauses and other mechanisms recognized by Serbian and EU data protection laws.

8. Data Retention

We store personal data only for as long as necessary:

– messenger account data is kept for the duration of your account; – log files may be stored up to 12 months; – payment data is stored according to Serbian accounting regulations; – support messages may be stored up to 12 months after resolution.

Data is deleted when retention is no longer required or when the user requests deletion, unless the law provides otherwise.

9. User Rights

You have the following rights regarding your personal data:

– right to access and obtain a copy of your data; – right to correct or update your data; – right to request deletion (“right to be forgotten”); – right to restrict processing; – right to withdraw consent; – right to object to certain processing activities based on legitimate interests; – right to data portability; – right to file a complaint with the competent Serbian authority.

Requests may be sent to: info@grailgun.ai

10. Security Measures

We apply technical, organizational and legal measures to protect personal data against unauthorized access, alteration, loss, destruction or disclosure.

These measures include encryption, restricted access, secure storage, monitoring and contractual obligations for third-party processors.

11. Cookies

The Website uses cookies to enable its functionality, maintain user sessions and gather anonymous analytics.

You can disable cookies in your browser settings, though this may affect Website performance.

12. Changes to the Privacy Policy

We may update this Policy when necessary.

The latest version is always available at https://grailgun.ai/privacy

Continued use of the Service after changes indicates acceptance of the updated Policy.

13. Contact Information

For any questions or requests regarding this Privacy Policy, please contact: info@grailgun.ai

MILANA FEDOTOVA PR Preduzetnik, Serbia PIB: 114956391 Registration No: 67981804 Address: Tikveška 19, Voždovac, Belgrade, 11050