1. Introduction
Orchestra ("we", "us", "our") provides a management portal for deploying and configuring AI agent teams at hiorchestra.com. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and your rights as a data subject under the EU General Data Protection Regulation (GDPR) and other applicable privacy laws.
By using the Service, you agree to the practices described in this Privacy Policy.
Plain Language Summary
We do not sell your data. We do not track you across websites. We do not read your conversations or agent outputs. We do not store the content of messages, emails, or files your agents process.
When your agents call AI providers (Anthropic, OpenAI, etc.), those calls go directly to their servers under their own privacy policies — the same as using ChatGPT or Claude directly. Orchestra is not in that data flow.
What we do store: your email address, OAuth tokens for integrations you connect, and your agent configuration and API keys (encrypted). Nothing else.
2. Data Controller and Data Processor
2.1 Data Controller — Orchestra is the data controller for personal data collected directly from users for the purpose of operating the Service, such as your email address and account information.
2.2 Data Processor — When you deploy Agents that access, process, or interact with personal data belonging to third parties (for example, reading emails from your Gmail, processing contacts, or interacting with external services on your behalf), Orchestra acts solely as a data processor. You, as the user, are the data controller for that data and are responsible for ensuring a lawful basis for its processing.
A Data Processing Agreement (DPA) is available at hiorchestra.com/dpa for users who require it for GDPR compliance purposes. For a countersigned copy, contact legal@hiorchestra.com.
3. Legal Basis for Processing
We process your personal data under the following legal bases:
Performance of a contract (Article 6(1)(b) GDPR): Processing your account information and configuration data is necessary to provide the Service you have signed up for.
Legitimate interests (Article 6(1)(f) GDPR): We process basic website analytics data to understand how the Service is used and improve it. This does not involve tracking individual users across sessions.
Consent (Article 6(1)(a) GDPR): Where you explicitly connect third-party accounts (Google, Telegram, etc.), you provide consent for Orchestra to store the access tokens required to operate those integrations on your behalf.
4. Information We Collect
4.1 Account Information — When you create an account, we collect your email address for authentication. We use a passwordless one-time-code (OTP) system. We do not store passwords.
4.2 Third-Party OAuth Tokens — If you connect third-party accounts (Google services including Gmail, Calendar, Drive, Contacts, Sheets, and Docs; or Telegram), we store the OAuth refresh token required to maintain that integration. We do not store your passwords for any third-party service. You can revoke these tokens at any time from the Channels page.
4.3 Agent and Instance Configuration — We store your agent deployment settings, including: AI provider API keys (encrypted at rest), channel configurations, and agent definitions. These are stored solely to operate the Service on your behalf.
4.4 Automatically Collected Technical Data — When you access the Service, we automatically collect certain technical information from your device and browser. This may include: IP address (which may constitute personal data under applicable law, including GDPR), browser type and version, operating system and device type, referring URLs, pages visited within the Service, timestamps and session duration. This information is used for security monitoring, abuse prevention, and aggregate analytics. We do not use it to build individual user profiles.
4.5 Website Analytics — We collect anonymised, aggregate analytics data about how our website is used (page visits, navigation patterns, feature usage). This data does not identify individual users and is used solely to improve the Service. We do not use advertising trackers or cross-site tracking.
4.6 What We Do Not Collect — Orchestra does not log the content of agent executions, the data accessed or processed by agents during their operation, the content of emails, files, or messages read or sent by agents, or the outputs generated by AI models. We have no visibility into what your agents do at runtime.
5. AI Model Providers
Orchestra does not provide AI models. Users connect their own API keys from their chosen AI providers (such as Anthropic, OpenAI, Google AI, or others). Orchestra stores these API keys in encrypted form solely to authenticate requests made by your agents.
When your agents make calls to AI providers using your API keys, those requests go directly to the provider's servers and are governed by their own privacy policy and terms of service. This is functionally identical to using ChatGPT, Claude, or any other AI service directly — Orchestra is not in that data flow and has no visibility into the content of those requests or responses.
Orchestra does not intermediate, log, store, or have access to the content of AI provider API calls made by your agents. Users are responsible for reviewing and accepting the terms of their chosen AI providers.
6. Data Storage and Security
Your data is stored in a PostgreSQL database hosted on Railway infrastructure, located in the European Union. All connections use HTTPS/TLS encryption in transit. Sensitive credentials (API keys, OAuth tokens) are encrypted at rest.
We follow industry-standard security practices to protect your data from unauthorised access, disclosure, or destruction. We do not guarantee absolute security.
In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you without undue delay and in any case within 72 hours of becoming aware of the breach, as required by GDPR Article 33.
7. Sub-Processors
To provide the Service, we use the following sub-processors who may have access to your data:
Railway (railway.app): Cloud infrastructure provider. Hosts our database and application servers. Data stored in EU region.
Google LLC: Used for Google OAuth integrations (Gmail, Calendar, Drive, Contacts, Sheets, Docs) when explicitly authorised by the user.
Telegram Messenger: Used for Telegram channel integrations when explicitly authorised by the user.
WhatsApp (Meta Platforms): Used for WhatsApp integrations when explicitly authorised by the user.
Discord: Used for Discord integrations when explicitly authorised by the user.
Slack Technologies: Used for Slack integrations when explicitly authorised by the user.
Other messaging or collaboration platforms may be added as integrations are released. AI model providers (Anthropic, OpenAI, Google AI, and others) are not sub-processors of Orchestra. They are independent services accessed directly via the user's own API keys. Orchestra does not share data with them on behalf of users.
8. Data Retention
We retain your data for as long as your account is active. Specific retention periods by data type:
Account email address: Retained for the duration of your account. Deleted within 30 days of account deletion request.
OAuth tokens: Retained until you disconnect the relevant integration or delete your account. Revocable at any time from the Channels page.
API keys and agent configurations: Retained until you delete them or your account. Deleted within 30 days of account deletion request.
Website analytics: Aggregated and anonymised. No individual-level retention.
You may request deletion of your account and all associated data at any time by contacting legal@hiorchestra.com. We will process deletion requests within 30 days.
9. Your Rights Under GDPR
If you are located in the European Union or European Economic Area, you have the following rights:
Right of access: You may request a copy of the personal data we hold about you.
Right to rectification: You may request correction of inaccurate or incomplete data.
Right to erasure: You may request deletion of your personal data, subject to legal retention obligations.
Right to restriction: You may request that we restrict processing of your data in certain circumstances.
Right to data portability: You may request your data in a structured, machine-readable format.
Right to object: You may object to processing based on legitimate interests.
Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at legal@hiorchestra.com. We will respond within 30 days. You also have the right to lodge a complaint with your national data protection authority.
10. Third-Party Services
The Service integrates with third-party platforms at the user's explicit request. Each integration is governed by the third party's own privacy policy. Orchestra only accesses the scopes explicitly authorised by the user and does not share user data with third parties for marketing or advertising purposes.
You are responsible for reviewing and accepting the terms and privacy policies of each service you connect to Orchestra. Supported integrations currently include: Google services (Gmail, Calendar, Drive, Contacts, Sheets, Docs), Telegram, WhatsApp, Discord, Slack, and AI providers (Anthropic, OpenAI, Google AI, and others).
11. Cookies and Tracking
Orchestra does not use advertising cookies or cross-site tracking technologies. We use minimal, anonymised analytics to understand website usage patterns in aggregate. No cookies that identify individual users are set without consent. You can disable analytics tracking through your browser settings.
12. Minimum Age and Children's Data
The Service is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors under 18. If you are under 18 years of age, you may not use the Service.
If we become aware that personal data has been collected from a user under 18 without verifiable parental or guardian consent, we will take all reasonable steps to delete such information from our systems as promptly as possible. If you believe a minor has provided us with personal data, please notify us immediately at legal@hiorchestra.com.
13. Communications and Opt-Out
Orchestra may send you the following types of communications by email: (a) transactional emails necessary to operate the Service, such as one-time login codes, account confirmations, and security alerts — these cannot be opted out of while your account is active; (b) product updates and announcements about material changes to the Service or these policies; and (c) optional service communications such as tips, feature releases, or newsletters, which you may opt out of at any time.
To opt out of non-transactional communications, click the "unsubscribe" link included in any such email, or contact us at legal@hiorchestra.com. We will process opt-out requests within a reasonable time. Note that opting out of marketing emails does not affect delivery of transactional communications.
14. International Data Transfers
Our servers are located in the European Union. If you access the Service from outside the EU, your personal data may be transferred to and processed in the EU, where data protection laws may differ from those in your country.
For transfers of personal data from the EU to any third countries involved in our sub-processor chain, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions, or other lawful transfer mechanisms under GDPR Chapter V.
By using the Service, you acknowledge and agree to the transfer and processing of your personal data in the EU as described in this Privacy Policy.
15. No Third Party Beneficiaries
This Privacy Policy does not create rights enforceable by third parties. It is intended solely for the benefit of Orchestra and its users. No third party shall have any right to enforce any provision of this Privacy Policy.
16. Relationship to Terms and Conditions
This Privacy Policy is incorporated by reference into Orchestra's Terms and Conditions of Use. By using the Service, you agree to both documents. In the event of any conflict between this Privacy Policy and the Terms, this Privacy Policy shall govern with respect to privacy and personal data matters.
17. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify registered users of material changes via email at least 15 days before the changes take effect. The current version will always be available at hiorchestra.com/privacy.
18. Contact and Data Protection Inquiries
For any questions, requests, or complaints regarding this Privacy Policy or our data practices, contact us at: legal@hiorchestra.com
For GDPR-specific requests including DPA inquiries, data subject rights requests, or breach notifications, please use the same address with the subject line "GDPR Request".