Privacy Policy
Last updated: 20 May 2026
01Introduction and Identity of the Data Controller
This Privacy Policy (“Policy”) is issued by Royal Softworks (“Company,” “we,” “us,” or “our”), a software company organised and operating under the laws of the Republic of Serbia, with its principal place of business in Kragujevac, Republic of Serbia. This Policy governs the collection, processing, storage, disclosure, and use of personal data in connection with the Company’s website located at https://royalsoftworks.com(the “Website”) and any related software products and services made available through the Website (collectively, the “Services”).
Royal Softworks acts as the data controller with respect to personal data collected through the Website. For all privacy-related inquiries, please contact: office@royalsoftworks.com.
02Scope
This Policy applies to: (a) all visitors to, and users of, the Website (royalsoftworks.com); (b) all account holders and users of the Company’s customer dashboard, licence-management portal, and affiliate programme; and (c) all account holders, organisations, and end-users of the Company’s cloud-hosted services, including without limitation AssistantGeneral Cloud, the DocumentConverter API, JokeService, and any other hosted offering made available under the Royal Softworks brand (collectively, the “Cloud Services”).
On-premise desktop products (e.g. AssistantGeneral desktop, Privatta, DuplicateDuster, OfficeBrief, Space Wizard, VoiceMe). These products run exclusively on end-user hardware. Content generated or processed within them (e.g. chat messages, indexed documents, transferred files, voice transcripts) is not transmitted to Royal Softworks. The Company nonetheless processes a limited set of account and licence-validation data described in §3.2 when you sign in to the customer dashboard or when the desktop product validates its licence online.
Cloud Services.Where you use a Cloud Service, the content you submit is necessarily transmitted to and stored on Royal Softworks’ infrastructure (or on infrastructure operated by the sub-processors identified in §5) so that the Service can function. Sections 3.7 through 3.10 describe in detail what is collected and how it is processed.
03Personal Data We Collect and the Legal Basis for Processing
3.1 — Server Access Logs
Our web server automatically records standard technical access log data each time a device connects to the Website. Such data includes, without limitation: the Internet Protocol (“IP”) address of the connecting device, browser type and version, operating system, any referring URL, the pages or resources requested, and the date and time of the request (collectively, “Access Logs”).
This logging is an inherent and non-optional function of web server software. Royal Softworks does not exercise meaningful control over, nor can it readily circumvent, this server-level logging without impairing the operational security and integrity of the Website. Access Logs are retained for security monitoring and incident investigation purposes only and are not used for commercial profiling. The legal basis for this processing is the Company’s legitimate interest (Article 6(1)(f) GDPR / Article 12 LPDP) in maintaining website security, detecting and investigating suspicious or unauthorised access, and complying with applicable legal obligations.
3.2 — User Account and Software Licence Data
When you register for a user account on the Website, the following categories of personal data are collected: email address, first name, last name, and a password (stored as a one-way hash by our licensing sub-processor, Keygen.sh — see §5). When you subsequently activate the Company’s desktop software on a machine, the following additional device-level data may be collected: a hardware fingerprint (a non-reversible, pseudonymous identifier derived from device hardware characteristics), a machine display name, the platform designation (e.g., Windows, macOS, Linux), and the IP address of the device at the time of activation.
If you join the Company’s affiliate programme, an additional affiliate code, commission rate, conversion log, and payout ledger are stored against your account. Where you are an administrator or member of a Cloud Service organisation (“org”), your organisation membership, role, and the org’s licence tier are also stored. The legal basis for this processing is the performance of a contract to which the data subject is party (Article 6(1)(b) GDPR).
3.3 — Payment and Billing Data
Royal Softworks does not collect, process, handle, or store any payment card data, bank account information, or other financial credentials. All payment processing is performed exclusively by Paddle.com Inc.(“Paddle”), which acts as the merchant of record for all transactions conducted through the Website. Paddle’s collection and use of payment data is governed solely by Paddle’s own privacy policy and terms of service, over which Royal Softworks exercises no control.
Royal Softworks receives only non-sensitive transactional metadata issued by Paddle (e.g., a Paddle-generated transaction identifier, subscription identifier, and customer identifier) for the limited and sole purpose of verifying completed purchases and provisioning the corresponding software licences.
3.4 — Contact Form Data
When you submit an inquiry through the contact form available on the Website, the following personal data may be collected: your email address, first name, last name, company name, and the content of your inquiry message. Such data is transmitted directly to and stored by HubSpot, Inc.(“HubSpot”), the Company’s third-party customer relationship management provider, whose servers for this account are located in the European Union (EU1 region).
The personal data submitted through the contact form will be used primarily to respond to your specific inquiry. If you have expressly and separately consented to the receipt of marketing communications from Royal Softworks at the time of form submission, the Company may additionally use your contact information to send you information regarding its products and services. You may withdraw such consent at any time, without affecting the lawfulness of any processing carried out prior to withdrawal, by contacting us at office@royalsoftworks.com or by using the unsubscribe mechanism included in any such marketing communication. The applicable legal basis is either: the performance of a pre-contractual measure (Article 6(1)(b) GDPR) or consent (Article 6(1)(a) GDPR), as the case may be.
3.5 — Analytics Data (Conditional on Consent)
Subject to your prior, freely given, specific, and informed consent, the Website uses Google Analytics, a web analytics service provided by Google LLC(“Google”), to collect anonymised and aggregated data regarding visitor interaction with the Website. This may include: pages and content visited, approximate session duration, device type and browser version, approximate geographic location derived from a truncated (anonymised) IP address, and referral traffic source. IP addresses are anonymised prior to storage. Google Analytics cookies are placed on your device only if you affirmatively grant consent through the cookie consent interface presented upon your first visit to the Website.
The legal basis for this processing is consent (Article 6(1)(a) GDPR). You may withdraw consent at any time by managing your preferences as described in our Cookie Policy.
3.6 — Cookie and Local Storage Data
Please refer to our Cookie Policy for complete information regarding the specific cookies and local storage entries used on the Website, their purpose, duration, and the choices available to you.
3.7 — Cloud Service Content (Chat, Documents, Workflows)
Where you use a Cloud Service, the content you actively submit to that Service is stored on Royal Softworks’ infrastructure (or on the infrastructure of the storage sub-processors identified in §5) so that the Service can deliver its functionality. Depending on the Service and the features enabled, this may include: chat messages and conversation history, files you upload for retrieval-augmented generation (“RAG”) or document management, workflow definitions and execution logs, calendar / connector synchronisation data you have opted into, voice transcripts and Text-to-Speech (TTS) request payloads, and the metadata associated with each of the foregoing (timestamps, owning user, owning organisation).
Cloud Service content is scoped to the owning organisation by row-level isolation in our database (each record carries an immutable orgId) and to the owning user by access-control rules enforced at every read and write. Royal Softworks personnel do not routinely access user content; access is limited to support cases you have explicitly opened, audited incident response, and database administration performed under standard operational safeguards. The legal basis for this processing is the performance of a contract to which the data subject is party (Article 6(1)(b) GDPR).
3.8 — Third-Party AI Provider Data (BYOK)
Cloud Services that perform language-model inference operate, at launch, on a “bring your own key” (BYOK) basis. Before you can use chat or RAG features, you (or, for TEAM/ENT tiers, your organisation administrator) must paste an API key for a third-party AI provider — currently Anthropic (Claude) or OpenAI — or configure an endpoint URL for a self-hosted model server (e.g. Ollama, vLLM, LM Studio). The API key is encrypted at rest using AES-256-GCM with a server-held encryption key and is never transmitted back to the browser in plaintext.
When you submit a prompt, the prompt text, attached file excerpts retrieved from your RAG knowledge base, and the model’s response are transmitted to the third-party AI provider whose key you supplied. Royal Softworks does not aggregate, fine-tune on, or train its own models from this content. The provider’s processing of the prompt is governed exclusively by that provider’s own privacy policy, data-handling commitments, and regional data-residency settings, over which Royal Softworks exercises no control. See Anthropic’s Privacy Policy and OpenAI’s Privacy Policy.
Royal Softworks may, in the future, enable a “managed AI” option in which the Company supplies the upstream model capacity using a shared provider key and bills customers in usage-based credits. Until and unless that option is explicitly activated for your account, no inference is performed on Royal Softworks-supplied keys. This Policy will be updated to reflect any change in that arrangement.
3.9 — Connector OAuth Tokens and Integration Credentials
Cloud Services support optional integrations (“Connectors”) with third-party services such as Google Workspace, GitHub, Telegram, WhatsApp, calendar providers, and messaging bridges. Where you choose to connect such a service, the OAuth access token, refresh token, account identifier, and any minimal profile metadata returned by the third-party provider are stored encrypted-at-rest against your user record (or, for org-level connectors, against the org record). Tokens are used solely to make API calls on your behalf as you explicitly request through the Service interface. Revoking a Connector through the Service UI deletes the stored token immediately; revoking access in the third-party provider’s own settings will likewise render the stored token unusable.
3.10 — Single Sign-On (SSO) Data — Enterprise Tier Only
Where an organisation on the Enterprise tier configures Single Sign-On (SAML 2.0 or OpenID Connect) for its members, the following additional data may be processed: the organisation’s SSO endpoint metadata (issuer URL, certificate, attribute mappings), and, for each end-user authenticating via SSO, the standard claims released by the organisation’s identity provider (typically: email address, display name, group memberships). Royal Softworks does not receive end-user credentials in SSO mode; authentication occurs at the customer’s identity provider and the Service receives only a signed assertion.
04Data the Company Does Not Collect or Process
Royal Softworks expressly does not:
- (a)collect, process, or store payment card details, bank account data, or other financial credentials — all payment processing is performed by Paddle (see §3.3);
- (b)use any Cloud Service content (chat messages, uploaded documents, workflows, voice transcripts, RAG indexes, connector data) to train, fine-tune, evaluate, or improve any general-purpose machine-learning model owned or operated by the Company;
- (c)share or disclose Cloud Service content with any third party for that party's own commercial purposes;
- (d)sell, rent, lease, license, or otherwise transfer personal data to third parties for monetary or other valuable consideration;
- (e)engage in automated decision-making, including profiling, that produces legal effects or otherwise similarly significantly affects data subjects; or
- (f)knowingly collect personal data from individuals under the age of sixteen (16) years. If you become aware that a child under 16 has provided personal data to Royal Softworks without appropriate consent, please contact us at office@royalsoftworks.com immediately.
05Disclosure of Personal Data to Third-Party Processors
Royal Softworks engages the following sub-processors and discloses personal data only to the extent strictly necessary for the purposes described in this Policy:
| Third Party | Role | Data Shared | Location |
|---|---|---|---|
| Paddle.com Inc. | Payment processor (merchant of record) | Transactional metadata only (no financial data) | United Kingdom |
| Keygen.sh | User account & licence management | Email, name, password hash, licence keys, machine fingerprints, org metadata | United States |
| Supabase Inc. | Managed Postgres for Cloud Services (when enabled for an org) | Cloud Service content scoped to your org (chat, RAG indexes, workflows, settings) | EU (eu-west) by default; US region for US-residency customers |
| Amazon Web Services (S3) | Object storage for Cloud Service uploads (KB documents, attachments) | Files you upload to a Cloud Service knowledge base, scoped to your org prefix | EU (eu-west) by default; US region for US-residency customers |
| Anthropic, PBC | AI inference (BYOK — only when you supply your Anthropic key) | Prompt content, retrieved RAG excerpts, model output (per Anthropic's policy) | United States |
| OpenAI, L.L.C. | AI inference (BYOK — only when you supply your OpenAI key) | Prompt content, retrieved RAG excerpts, model output (per OpenAI's policy) | United States |
| OAuth providers (Google, GitHub, Microsoft, Telegram, WhatsApp, etc.) | Connector integrations (only those you explicitly enable) | Access tokens, refresh tokens, account identifier, the specific data you authorise the connector to access | Varies by provider |
| Identity provider (customer-controlled, ENT only) | Single Sign-On (SAML/OIDC) — only when an Enterprise org configures it | SSO assertions (typically email, display name, group memberships) | Customer-controlled |
| HubSpot, Inc. | CRM & contact form processor | Email, name, company, message content | EU (eu1 region) |
| SMTP / email infrastructure (cPanel-hosted) | Transactional email delivery (welcome, password reset, billing notices) | Email address, name, message content | EU |
| Google LLC | Web analytics — consent required | Anonymised usage and session data | United States |
| Google LLC | Font delivery (Google Fonts CDN) | IP address via browser font request | United States |
Royal Softworks does not disclose personal data to any other third party except: (a) as required by applicable law, court order, or binding instruction of a competent governmental authority; (b) as necessary to enforce the Company’s terms of service or to protect the legal rights, property, or safety of the Company, its users, or others; or (c) in connection with a merger, acquisition, reorganisation, or sale of all or substantially all of the Company’s assets, subject to appropriate notification to affected data subjects.
06International Data Transfers
Certain third-party processors referenced in this Policy are located outside the European Economic Area and outside the Republic of Serbia (notably, in the United States). Where such transfers occur, the Company ensures that appropriate safeguards are in place, including, as applicable, the European Commission’s Standard Contractual Clauses or other transfer mechanisms recognised under applicable data protection law.
The Company processes personal data in compliance with the Law on Personal Data Protection of the Republic of Serbia (Official Gazette of the Republic of Serbia, No. 87/2018, “LPDP”) and, where applicable, Regulation (EU) 2016/679 of the European Parliament and of the Council (the “GDPR”).
07Data Retention
| Data Category | Retention Period |
|---|---|
| Server access logs | Maximum 90 days; deleted or anonymised thereafter, unless required for a security investigation or by legal obligation |
| User account & licence data (Keygen) | Duration of account activity; deleted upon verified account removal request |
| Cloud Service content (chat, KB documents, workflows) | Duration of org subscription; deleted within 30 days of subscription termination or verified deletion request, whichever comes first. Backups purged on rolling 30-day cycle thereafter. |
| BYOK encrypted API keys | Until you replace or remove them in settings; cryptographically erased on org deletion |
| Connector OAuth tokens | Until you disconnect the connector or revoke at the provider; cryptographically erased on org deletion |
| Affiliate conversion / payout ledger | 7 years from last activity (statutory commercial-records retention) |
| Contact form data | Per HubSpot's data retention policy, or until deletion is requested by the data subject |
| Analytics data | Maximum 26 months within Google Analytics |
| Cookie consent preference | 12 months from date of setting, stored in browser local storage |
08Your Rights as a Data Subject
To the extent applicable under the LPDP and/or the GDPR, you are entitled to exercise the following rights in respect of your personal data:
Right of access (Art. 15 GDPR): You may request confirmation of whether we process your personal data and obtain a copy thereof.
Right to rectification (Art. 16 GDPR): You may request correction of inaccurate or incomplete personal data.
Right to erasure (Art. 17 GDPR): You may request deletion of your personal data, subject to applicable legal obligations or overriding legitimate interests.
Right to restriction of processing (Art. 18 GDPR): You may request that processing of your data be restricted in certain circumstances.
Right to data portability (Art. 20 GDPR): Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, machine-readable format.
Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests.
Right to withdraw consent (Art. 7(3) GDPR): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of the above rights, please submit a written request to office@royalsoftworks.com. The Company will respond within thirty (30) calendar days of receipt. If you consider that our processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia (www.poverenik.rs).
09Security
Royal Softworks implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, without limitation:
- (a)encrypted-in-transit communication: all browser-to-server and server-to-third-party traffic is conducted exclusively over TLS;
- (b)encrypted authentication: user sessions are managed via cryptographically signed, HTTP-only JWT cookies; cross-site cookies use SameSite=None with the Secure attribute;
- (c)encrypted-at-rest secrets: BYO API keys, connector OAuth tokens, and other sensitive credentials are stored encrypted with AES-256-GCM using a server-held key;
- (d)tenant isolation: Cloud Service data is segmented by organisation via mandatory orgId scoping at the application layer and, where supported (Supabase Postgres), Row-Level Security policies enforced at the database layer;
- (e)least-privilege access controls: production database and storage access is limited to a small number of operations personnel with audited credentials;
- (f)secure SDLC practices: code review on every change, dependency vulnerability scanning, security headers (CSP, HSTS, X-Frame-Options) on all responses; and
- (g)incident response: defined procedures for breach detection, containment, notification to affected data subjects, and notification to the competent supervisory authority within 72 hours where applicable.
Notwithstanding the foregoing, no method of electronic transmission or storage is completely secure, and the Company cannot warrant or guarantee absolute security.
10Governing Law and Jurisdiction
This Policy, and any dispute or claim arising out of or in connection with it or its subject matter or formation, shall be governed by and construed in accordance with the laws of the Republic of Serbia, without regard to its conflict of law provisions.
By accessing or using the Website or the Services in any capacity, you irrevocably and unconditionally agree to submit to the exclusive jurisdiction of the competent courts of Kragujevac, Republic of Serbia for the resolution of any dispute or claim arising out of or in connection with the Services, this Policy, or any matter related thereto. Nothing in this clause shall limit the right of Royal Softworks to seek injunctive or other equitable relief in any jurisdiction where permitted by applicable law.
11Changes to This Policy
Royal Softworks reserves the right to modify or update this Policy at any time. Material changes will be reflected by an updated “Last updated” date at the head of this document. Your continued use of the Website or the Services following the publication of any such changes shall constitute your acceptance of the revised Policy. You are encouraged to review this Policy periodically.
12Contact
For all privacy-related inquiries or to exercise your data subject rights: