Privacy Policy
1. Who is responsible for your data
The controller of the personal data processed through the Sales Intelligence website is Trotsenko Research Labs and Consulting OÜ, registry code 17547760, Kaupmehe tn 7-120, 10114 Tallinn, Estonia, email: hello@trlabs.ai (“TR Labs”, the “Company”).
The Company is not required to appoint a Data Protection Officer and has not done so. For any question about your data, write to hello@trlabs.ai.
This Policy follows the EU General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP) for visitors in Switzerland, and the Law of Ukraine “On Personal Data Protection”.
2. What data is processed
Form data. Full name, work email or phone, company name and team size that you enter in a form.
Technical data. When you open the website, our hosting provider processes your IP address, browser type, requested page and time of the request in server logs. This is needed to deliver the website and keep it secure.
Data stored in your browser. The website stores your cookie choice and, if you switch it, your preferred language in your browser’s local storage. It does not set cookies and does not use analytics or advertising tools. Fonts are served from our own server, so no data is sent to font providers.
Platform data. Call recordings, messages, emails, CRM data and data from other client systems are processed only after a contract is signed and only to the extent agreed in writing. For this data the Company acts as a processor on behalf of the client, and the client is the controller (see the Data Processing Agreement in the Terms of Service).
3. Purposes and legal bases
Answering your request, running a demo and preparing an offer – basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR). Following up with you as a business contact about that request – basis: our legitimate interest in answering business enquiries (Art. 6(1)(f) GDPR).
Providing the platform and support – basis: performance of a contract (Art. 6(1)(b) GDPR).
Delivering the website, keeping it secure and storing the choices you make on it – basis: our legitimate interest in a working, secure website (Art. 6(1)(f) GDPR); storing your choices in your browser is strictly necessary for a function you request.
Meeting tax and accounting obligations – basis: legal obligation (Art. 6(1)(c) GDPR).
Giving us your data is voluntary. Without contact details we cannot answer your request.
We do not make decisions about website visitors based solely on automated processing, including profiling (Art. 22 GDPR).
4. How the platform processes conversations
Personal data in conversations is pseudonymised before it is passed to an AI model.
The platform uses only enterprise AI services that are contractually bound not to train on client data.
Access is limited to what a specific task needs. Nothing is written to the client’s systems without the client’s permission.
If data cannot leave the client’s company, the platform is deployed as Sovereign AI in the client’s own infrastructure.
5. Who data may be shared with
Hosting and cloud infrastructure providers, enterprise AI services, email and messaging services (including Telegram, used to notify our team of new form requests), and accounting and legal advisers. Each of them processes data only under a contract and on the Company’s instructions. A current list of these service providers and their countries is available on request.
If data is transferred outside the EU/EEA or Switzerland, this is based on an adequacy decision or on the EU Standard Contractual Clauses (with the Swiss addendum where needed). You can request a copy of these safeguards at hello@trlabs.ai.
Data is not sold and is not shared with third parties for their marketing.
6. Retention period
Request data – up to 24 months after the last contact if no contract is signed.
Server logs – only as long as needed for security, then deleted by the hosting provider.
Your cookie choice – 12 months, after which the website asks again. Your language choice – until you clear your browser storage.
Contract data – for the term of the contract and up to 7 years after it ends where accounting law requires.
Platform conversation data – for the period agreed with the client in the contract, after which it is deleted or returned to the client.
7. Your rights
You have the right to access your data, have it corrected or deleted, restrict processing, receive it in a portable format, and object at any time to processing based on our legitimate interest. Where processing is based on consent, you can withdraw it at any time without affecting earlier processing.
To exercise a right, write to hello@trlabs.ai. We reply within one month; for complex requests this can be extended by two further months, and we will tell you if so. Exercising your rights is free of charge.
You can lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or with the supervisory authority in the EU/EEA country where you live or work. In Switzerland you can contact the Federal Data Protection and Information Commissioner (FDPIC); in Ukraine, the Ukrainian Parliament Commissioner for Human Rights.
8. Security
The Company uses encryption in transit and at rest, role-based access control, activity logging and regular backups. If a personal data breach is likely to result in a high risk to you, we will inform you without undue delay.
9. Changes to this Policy
The current version is always published on this page with its date. Platform clients are notified of material changes by email.
Terms of Service
1. General provisions
This document is a public offer by Trotsenko Research Labs and Consulting OÜ (the “Provider”) to enter into an agreement for access to the Sales Intelligence platform (the “Platform”).
The agreement is concluded upon acceptance: payment of the first invoice or signing of an order. The person who accepts is hereinafter the “Client”.
The offer is intended for legal entities and individual entrepreneurs.
2. Subject of the agreement
The Provider gives the Client access to the Platform under the selected plan, and the Client pays for it on the terms of this offer.
Features, user limits and analysis minutes are defined by the plan published on the website or agreed in the order.
3. Plans and payment
Basic and Pro plans are paid monthly or annually in advance. Prices are in US dollars, excluding VAT. The Individual plan is priced individually.
Payment is made by invoice within 5 banking days. Access is provided once payment is received.
Additional services (AI agents, minute packs, onboarding) are paid separately under an agreed order.
The Provider may change prices with at least 30 days’ notice to the Client. The new price applies from the next paid period.
4. Onboarding
The Provider connects communication channels and sets up evaluation criteria together with the Client. The scope of access to the Client’s systems is agreed in writing before work starts.
5. Rights and obligations of the parties
The Provider undertakes to keep the Platform running, provide support and keep the Client’s data confidential.
The Client undertakes to pay on time, provide the necessary access and not to use the Platform for unlawful purposes.
As controller of the conversation data, the Client is responsible for having a legal basis for recording and analysing conversations; for informing its customers and employees about it (including notifying the other party of recording where the law requires); for involving employee representatives where national law requires; and for carrying out a data protection impact assessment where Art. 35 GDPR requires. The Provider assists the Client with this as set out in section 6.
6. Client data and Data Processing Agreement (Art. 28 GDPR)
All data uploaded or received from the Client’s systems remains the Client’s property. For this data the Client is the controller and the Provider is the processor. This section is the data processing agreement between them.
Subject and duration. Processing of the Client’s conversation data and related CRM data to provide the Platform, for the term of the agreement.
Nature and purpose. Transcription, analysis against the Client’s criteria, reporting, suggestions and the other Platform functions the Client uses.
Data and data subjects. Recordings, messages, emails and CRM records; the Client’s employees, its customers and their contact persons.
Instructions. The Provider processes the data only on the Client’s documented instructions, which are this agreement, the order and the Client’s settings in the Platform, and informs the Client if an instruction appears to infringe data protection law.
Confidentiality. Everyone at the Provider with access to the data is bound by confidentiality.
Security. The Provider applies appropriate technical and organisational measures (Art. 32 GDPR), including encryption in transit and at rest, role-based access control, logging, pseudonymisation before AI processing and backups.
Sub-processors. The Client gives general authorisation to use sub-processors (hosting, cloud infrastructure, enterprise AI services). The Provider keeps a current list, informs the Client of intended changes at least 30 days in advance, and the Client may object on reasonable grounds. Each sub-processor is bound by the same data protection obligations. Transfers outside the EU/EEA rely on an adequacy decision or the EU Standard Contractual Clauses.
Assistance. The Provider helps the Client respond to data subject requests, carry out data protection impact assessments and meet its security and breach-notification obligations.
Breaches. The Provider notifies the Client of a personal data breach without undue delay, and no later than 48 hours after becoming aware of it.
End of processing. After termination the data is returned to the Client or deleted within 30 days, unless law requires storage.
Audits. The Provider makes available the information needed to demonstrate compliance and allows audits by the Client or an auditor it appoints, with reasonable notice.
7. Support
Support is provided by email and in working messengers on business days. The Pro plan includes 2 hours of consulting and 2 hours of development per month for the Client’s needs; unused hours do not roll over.
8. Liability
The Provider’s total liability under the agreement is limited to the amount paid by the Client for the last 3 months.
The Provider is not liable for decisions made by the Client based on Platform data, or for failures of third-party systems.
9. Term and termination
The agreement runs for the paid period and renews automatically for the next one unless the Client cancels.
The Client may cancel renewal at any time by notifying the Provider by email. Access remains until the end of the paid period. Fees paid for the current period are not refunded, except where the law provides otherwise.
10. Force majeure
The parties are released from liability for failure to perform obligations due to force majeure for as long as it lasts.
11. Governing law and disputes
The agreement is governed by the law of the Republic of Estonia. Disputes are resolved by negotiation and, failing agreement, in Harju Maakohus (Tallinn), unless the parties agree otherwise.
12. Provider details
Trotsenko Research Labs and Consulting OÜ, registry code 17547760, address: Kaupmehe tn 7-120, 10114 Tallinn, Estonia, email: hello@trlabs.ai.
Cookie Policy
Summary
The website does not set cookies and does not use analytics or advertising tools. It keeps two small entries in your browser’s local storage, both strictly necessary for functions you use, so no consent is required for them.
What is stored
si-cookie-consent – your choice in the cookie settings. Kept for 12 months, then the website asks again.
si-lang – the language you picked in the language menu, so the website opens in it next time. Kept until you clear your browser storage.
Analytics and marketing
The “Analytics” and “Marketing” switches in the cookie settings are reserved for future use. No such tools are active now. If we add one, it will run only after you switch it on, and this policy will name the tool, its provider and storage period first.
How to manage your choice
You can change your choice at any time via “Cookie settings” at the bottom of the website, or delete stored data in your browser settings.
If your browser sends a privacy signal (Global Privacy Control or Do Not Track), the website treats it as “Deny all” and does not show the banner.
