Legal Document

Privacy Policy

Effective date: May 18, 2026  ·  Version 1.1
01

Who We Are

Grawx is an AI-powered marketing automation service accessible via the Telegram bot t.me/grawx_bot and the website grawx.com.

The service is provided by:

EntityJan Košak s.p.
AddressDolenjska cesta 73, 1000 Ljubljana, Slovenia
Tax ID (DDV)SI66877342
Registration9832190000

We act as the data controller for all personal data processed through Grawx.

02

What Data We Collect

We collect only what is necessary to provide and improve the service.

Data TypeWhat ExactlyWhy
Telegram User IDA unique numeric identifier assigned by Telegram. We do not collect your username, name, phone number, or profile photo.To identify your account, store credits, and send bot messages.
Business InformationYour website URL, niche, target audience, brand voice, product details, CTA preferences, and anything you voluntarily provide during onboarding or automation setup.To generate marketing content tailored to your business.
Usage DataAccount creation and last-activity timestamps, selected timezone, content generation count, automation settings.To schedule content, manage credits, and improve service quality.
Generated Content HistoryFull text of generated content stored for up to 30 days, then permanently deleted. Metadata (hook type, tone, ratings, scores) retained longer.A/B testing, performance tracking, and quality improvement.
Payment RecordsAmount paid, credit package, purchase date, and Stripe transaction reference ID. We never store card numbers or bank details.Billing records and financial compliance.
Referral DataTelegram user IDs of referring and referred users.To attribute and award referral credits.
API Usage LogsAI model name, token count per operation, timestamp. No message content is stored in logs.Cost monitoring and capacity planning.
We do not collect: your real name, email address, phone number, location, IP address, device information, browser cookies, or any data from your social media accounts.
03

How We Use Your Data

Service delivery: Generating marketing content based on your business information and preferences.

Account management: Tracking credits, processing purchases, managing automation schedules.

Service improvement: Analysing aggregated, anonymised performance data. Individual user data is never used to train third-party AI models.

Communications: Sending generated content, updates, and service notifications via Telegram. We do not send unsolicited marketing messages.

Legal compliance: Retaining financial records as required by Slovenian and EU accounting regulations.

04

Legal Basis for Processing (GDPR)

Processing ActivityLegal Basis
Delivering the Grawx servicePerformance of a contract (Art. 6(1)(b) GDPR)
Processing paymentsPerformance of a contract (Art. 6(1)(b) GDPR)
Retaining financial recordsLegal obligation (Art. 6(1)(c) GDPR)
Service improvement and analyticsLegitimate interests (Art. 6(1)(f) GDPR)
Service notifications via TelegramPerformance of a contract (Art. 6(1)(b) GDPR)
05

Third-Party Services & Data Transfers

We share only the minimum data required for each provider to function.

International transfers: Anthropic, OpenAI, and xAI are US-based. Data sent to their APIs may be processed in the US. All three maintain Standard Contractual Clauses or equivalent GDPR safeguards. Stripe maintains EU–US Data Privacy Framework certification.
06

Data Retention

DataRetention Period
Full generated content text30 days, then permanently deleted
Content metadata (type, tone, scores, ratings)Duration of your account
Business informationDuration of your account
Purchase records10 years (Slovenian accounting law)
Account data (user ID, credits, timestamps)Duration of account + 30 days after deletion
API usage logs90 days
07

Your Rights Under GDPR

To exercise any right below, contact hello@grawx.com. We respond within 30 days.

Right of Access

Request a copy of all personal data we hold about you.

Right to Rectification

Ask us to correct inaccurate or incomplete data.

Right to Erasure

Request deletion of your account and all associated data, subject to legal retention obligations.

Right to Portability

Receive your business data in a structured, machine-readable format.

Right to Restrict

Ask us to pause processing your data in certain circumstances.

Right to Object

Object to processing based on legitimate interests.

You may also lodge a complaint with Slovenia's supervisory authority: Informacijski pooblaščenec at ip-rs.si.

08

Children's Privacy

Grawx is not intended for anyone under 16 years of age. We do not knowingly collect data from children under 16. Contact hello@grawx.com immediately if you believe a minor has used the service.

09

International Users & Jurisdiction-Specific Rights

Grawx is available worldwide. As an EU-based company we apply GDPR as our baseline — one of the strictest frameworks globally. All users benefit from the same high level of protection regardless of location.

United Kingdom: UK GDPR applies. Your rights are equivalent to Section 7. Supervisory authority: ICO (ico.org.uk).

California, USA (CCPA/CPRA): We do not sell your personal information. California residents may request to know, delete, and opt out of any future sale. Contact hello@grawx.com.

Brazil (LGPD): Rights to access, correction, deletion, and portability apply as in Section 7. Supervisory authority: ANPD.

Australia: Australian Consumer Law guarantees apply and cannot be excluded.

All other jurisdictions: Where local law provides stronger rights, those apply. Contact us with jurisdiction-specific questions.

10

Cookies & Tracking

Our website grawx.com uses cookies and similar tracking technologies. We do not set any non-essential cookies without your explicit consent, which you can provide or withdraw at any time via the cookie banner on our site.

Essential cookies are required for the site to function and are set automatically. Marketing cookies — including the Meta (Facebook) Pixel — are only activated after you give consent. The Pixel allows us to measure the effectiveness of our advertising and, if you have a Facebook account, may be used by Meta to show you relevant ads.

You can change or withdraw your consent at any time by clicking the cookie settings link in the banner. For more about how Meta uses this data, see facebook.com/privacy/explanation.

The full list of cookies used on this site:

11

Security

All API communications use encrypted HTTPS. Our database is hosted on Railway's EU infrastructure with restricted access. Payment processing is handled entirely by Stripe — no card data touches our servers. While we apply industry-standard measures, no internet transmission is 100% secure.

12

Changes to This Policy

Material changes will be communicated via the Telegram bot at least 7 days before taking effect. Continued use after the effective date constitutes acceptance. Current version always at grawx.com/privacy-policy.

13

Contact

Data Controller Contact

For privacy questions, data requests, or complaints — we respond within 30 days.

EntityJan Košak s.p., Ljubljana, Slovenia
t.me/grawx_bot