Privacy Policy for Orchestrel Play

Introduction

Orchestrel AI ("we", "us", "our", or the "Company") is committed to protecting your personal data and being transparent about how we use it. This Privacy Policy explains what personal data we collect when you use Orchestrel Play ("Play" or the "Service"), why we collect it, and what your rights are under applicable data protection law, including the EU General Data Protection Regulation (GDPR).

Data Controller: Orchestrel AI SARL, 29 rue d'Esch, L-3920 Mondercange, Luxembourg.

1. Data We Collect

We collect the following categories of personal data:

• Account information: Your work email address (and any profile details you choose to add) necessary to create and manage your workspace.
• Workspace and lane configuration: The types and number of lanes you run, your billing status, and similar settings needed to operate your workspace.
• Usage metrics: Session counts, session duration, lane bandwidth, and fair-use status, used to bill correctly, enforce fair use, and keep the platform fast.
• Session content: When a lane runs an agent session, the session's content (code, prompts, tool outputs, and model responses) flows through Play. It is processed to run your work, and stored only as needed to maintain session continuity (resuming a session, preserving its state). It is never used to train models, ours or anyone else's, and is not shared with third parties beyond the model providers required to run your sessions.
• Payment information: Processed securely by our payment provider (Stripe or equivalent). We do not store credit card numbers or sensitive payment details on our servers.

2. What We Do NOT Do With Your Data

Play is a hosted agent service: to run your work, session content is necessarily processed on our infrastructure and sent to model providers for inference. What we do not do is just as important:

• No training. Session content is never used to train our models or anyone else's models.
• No sale or sharing beyond inference. We do not sell, rent, or trade personal data, and we do not share session content with any third party other than the model providers needed to run your sessions.
• No advertising or cross-site tracking. We do not use third-party analytics, advertising cookies, or cross-site tracking on the Service.
• No human review by default. Session content is not read by our team except when you ask us for support on a specific session, or where required for security, legal, or fair-use enforcement.

3. Purpose of Processing & Legal Basis

We process personal data for the following purposes:

• Account and workspace management: work email, configuration, contract performance (GDPR Art. 6(1)(b))
• Billing: lane counts, billing status, contract performance (GDPR Art. 6(1)(b))
• Running your sessions: session content, contract performance (GDPR Art. 6(1)(b)); this processing is the service you subscribe to
• Fair use and platform security: usage metrics, legitimate interest (GDPR Art. 6(1)(f))
• Service notifications: email address, contract performance (GDPR Art. 6(1)(b))

4. Data Retention

• Account data is retained for the duration of your active subscription, plus 30 days after cancellation or termination.
• Billing records are retained for the period required by applicable legal and tax authorities (a minimum of 10 years under Luxembourg law).
• Session content is retained as long as needed to maintain session continuity for your active lanes, and is deleted within 30 days after the related lanes are removed or the subscription ends (except where security or legal obligations require longer retention).
• Usage metrics (aggregate and anonymized) may be retained indefinitely for analytical purposes.
• Payment records are managed by our payment processor in accordance with their retention policies and PCI-DSS requirements.

5. Third Parties

We share limited personal data with the following categories of third parties:

• Model providers: Session content is transmitted to AI model providers, accessed via our routing infrastructure, to run inference for your sessions. This transmission is how the Service works. Note: model providers may process data on servers located outside the EU. We do not currently guarantee that all inference processing occurs within the EU.
• Payment processor: Stripe (or equivalent) for billing and payment processing.
• Infrastructure: Cloudflare is used for DNS and security. Netlify hosts our marketing website.

We do not sell, rent, or trade personal data. All third-party data sharing is strictly limited to what is necessary for the operation of the Service.

6. Your Rights (GDPR Articles 15 to 21)

Under the GDPR, you have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data, including session content, subject to legal retention obligations for billing records.
• Right to restriction of processing: Request that we limit how we process your personal data in certain circumstances.
• Right to data portability: Receive your personal data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interests.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

If you are located in the EU, you also have the right to lodge a complaint with the Luxembourg data protection authority (CNPD, Commission Nationale pour la Protection des Données).

7. Cookie Policy

We use minimal cookies on the Service:

• Session cookies: If you log into your Play dashboard, we use session cookies to maintain your authentication state. These are deleted when your session ends.
• No tracking cookies: We do not use third-party analytics, advertising cookies, or cross-site tracking.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption in transit (TLS 1.3+) for all communications
• Access controls and authentication for all internal systems
• Secrets guard: lanes monitor session content for sensitive material (API keys, tokens, credentials) and mask the value before it reaches a model
• No training: session content is never used to train models, ours or anyone else's

The secrets guard reduces risk but does not replace your own responsibility for the secrets you bring into a session: mask or revoke credentials where you can.

9. Contact

If you have any questions regarding this Privacy Policy or wish to exercise your rights, please contact us:

• Email: [email protected]
• Orchestrel AI SARL
• 29 rue d'Esch, L-3920 Mondercange, Luxembourg