Language notice: This English translation is provided for convenience. The Spanish version prevails in the event of any discrepancy.
Disclaimer: This document was prepared with AI assistance and is offered as a starting point only. It is not legal advice and does not create a lawyer-client relationship. Laws may change. A qualified legal professional in Spain should review it before publication or use. The tool's author accepts no liability for its use.
Draft: complete the highlighted fields, confirm the providers and publish the data processing agreement before using monitors.
Privacy policy
Last updated: .
1. Controller and contact
The controller of account, billing, security and business relationship data is Derek Sanz Chiorean, a self-employed professional with tax ID 47479047D and business address at Carrer De La Generalitat, 8, Alcanar, who provides Oteaya under the trade name Wakefold. Website: https://wakefold.com. Contact: [email protected].
2. Scope and roles
This policy applies to people who visit the website, create an account, receive a team invitation, use the application or API, purchase a plan, or contact us. Oteaya is intended for professionals and organisations.
For account, billing, security and platform-operation data, the provider acts as controller. For content a customer organisation enters or configures in its monitors, the organisation is the controller and Oteaya may act as processor only when processing that data on its documented instructions. Roles are determined by the specific processing and are not changed merely by the name of an agreement. Before enabling monitors that process personal data, the parties must complete and sign the data processing agreement template. The customer must determine and document its purposes and lawful basis, provide required notices and handle data-subject rights.
3. Data, purposes and legal bases
- Account, access and team: name, email address, securely stored password, sessions, invitations, team membership and permissions. Used to create and administer accounts, authenticate users, provide the service and handle requests. Legal basis: contract performance and, to prevent unauthorised access, our legitimate interest in protecting the service.
- Technical and security data: IP address and user agent associated with sessions, technical logs needed to operate the service, and API-key metadata. Used for authentication, incident investigation and platform security. Legal basis: contract performance and our legitimate interest in security. IP addresses and user agents associated with a session are retained while the session remains valid. The planned retention period for technical logs is no more than 30 days, except where a longer period is necessary to investigate an incident or meet a legal obligation. Automatic deletion still needs to be configured and verified before this period is applied and the policy is published.
- Monitor configuration and content: queries, sources, monitor names and context, schedules and analysis rules, together with matching news, public X posts and public Telegram-channel messages. Used to collect, display and classify information according to the plan and customer configuration. For content processed on the customer's behalf, the customer determines and documents the legal basis.
- Automated analysis: when enabled, the monitor name, description, criteria and schedule, together with the text and metadata of a news item, post or message, are sent to OpenAI to classify relevance, topic and priority. Oteaya presents the result as a reading aid and does not make automated decisions with legal or similarly significant effects on people. The customer must review results before using them.
- Billing: contact and billing details, purchased plan, payment status and transaction data. Stripe processes payments and full card details; Oteaya does not store the full card number. Legal basis: contract performance and compliance with tax and accounting obligations.
- Communications: your email address and the contents of requests you send us, used to respond, provide support and manage our relationship. Legal basis: responding to your request or performing the contract.
- Preferences stored on your device: identifiers for items marked as read and sound or desktop-notification preferences stored in your browser's local storage.
Data marked as required in the registration form is necessary to create an account or provide dependent features. We do not request special-category data; customers must not include it in monitor queries or content.
4. Providers and recipients
- Stripe: processes payments, billing data and contact details needed to manage subscriptions. Privacy information.
- OpenAI: receives monitor data and content described in section 3 when automated analysis is enabled. Privacy information.
- Transactional email: Resend, when configured, sends account verification, password reset and invitation messages. The recipient's email address and the content needed to deliver each message are shared, such as the inviter's name and organisation name in an invitation. The processing region depends on the Resend account settings and current terms and must be confirmed before publication. Resend privacy information.
- Hosting and database: infrastructure managed by the Provider in Spain. The application and PostgreSQL database run on a server located in Spain; no external hosting provider is used for this server.
- Backups: the documented procedure provides for daily backups, retained for 7 days on the server and up to 30 days in a remote storage service. Confirm that the task is active and identify the provider, storage region and safeguards actually configured before publishing this policy.
- Cloudflare: when visitors connect through its network, it processes IP addresses to deliver the connection and provides an approximate country used to estimate taxes. Cloudflare operates a global network; active services, processing locations and safeguards depend on the account configuration and current terms. Privacy information.
Data may also be received by customer-organisation members according to their permissions, platforms from which public posts are obtained (such as X and Telegram), news sources, and authorities where legally required. We do not sell personal data or use it for behavioural advertising.
5. International transfers
Some providers may process data outside the European Economic Area. In those cases, transfers will take place only under the mechanism applicable to the provider and destination, such as an adequacy decision or standard contractual clauses included in the provider's data-processing terms, together with any required supplementary measures. The region and safeguards for each provider account must be confirmed before the relevant service is enabled. You may request the applicable contractual information by emailing [email protected].
6. Retention and deletion
We retain account data while the account is active and afterwards for as long as needed to meet legal obligations and address liability or claims. You may request deletion at [email protected]. We retain data required by law or needed to establish, exercise or defend claims, and restrict it where appropriate.
Monitor content is retained according to plan history: currently 30, 90 or 180 days depending on the plan, and 30 days for the Incident pass. The period runs from an item's first collection, not from cancellation. When an organisation no longer has an active plan, a default maximum of 30 days from first collection applies, so older items may be deleted sooner. Content not associated with a monitor is purged sooner: news and X posts after 2 days, and public Telegram messages after 14 days. Account data is retained while the account is active and after a deletion request only for applicable legal or claims periods. The planned retention period for technical logs is no more than 30 days unless a longer period is justified; automatic deletion still needs to be configured and verified. Backups are retained for 7 days on the server and up to 30 days in the remote storage service when the documented task is active. Billing data is retained for applicable statutory periods.
7. Cookies and browser storage
Authenticated sessions use technical cookies needed to start and maintain a session. The application also stores notification preferences and identifiers for items marked as read locally in the browser. The current product code does not use analytics or advertising cookies; the deployed configuration must be reviewed before publication. If technologies not needed to provide a requested feature are introduced, the applicable prior consent will be requested.
8. Rights and complaints
Where applicable, you may request access, rectification, erasure, objection, restriction and portability by writing to [email protected]. We will respond within the legal period, normally one month. We may request reasonable information to verify your identity. If processing is based on consent, you may withdraw it at any time without affecting prior lawful processing. You may also complain to the Spanish Data Protection Agency at www.aepd.es. For data processed as controller by a customer organisation, contact that organisation; Oteaya will assist it under the data processing agreement and applicable law.
9. Security and changes
We apply reasonable technical and organisational measures to protect data, restrict access and manage incidents in light of service risks. No internet-connected system can guarantee absolute security. We will publish updates to this policy here with their effective date. If a change requires a new legal basis or prior information, we will provide it before starting that processing.
Items to complete before publication
- Confirm the processing regions and safeguards for Resend, Cloudflare, OpenAI, Stripe and the remote storage provider based on the active accounts and agreements.
- Complete and sign the data processing agreement template with each customer.
- Confirm that the backup task is active, identify the remote provider and region, and document its safeguards.
- Configure technical-log deletion within 30 days.
- Confirm the deployed cookie and browser-storage configuration.