Privacy policy

This policy explains how [Kelwick legal entity] handles personal data on the Kelwick website and in the Kelwick application. It covers visitors, people who use a Kelwick workspace, and people whose details appear in data Kelwick processes for a customer (for example a contact at one of a customer's customers).

For business data that Kelwick processes on a customer's instructions, the customer is the controller and we are the processor. [A data processing agreement for customers who need one: to be prepared with counsel.]

• Account details: name, work email, role, the company and branches you belong to, profile photo if you add one.
• Sign-in data: your password hash, your two-step sign-in settings (an authenticator app's secret, stored encrypted, or the mobile number codes are texted to), and when you last signed in. Your IP address is used briefly to limit repeated sign-in attempts and is not stored.
• Connections your company sets up: your Eclipse username, which Kelwick uses to act as you in Eclipse, and the Microsoft 365 mailboxes your company's admin lets Kelwick read. The secrets for your company's Eclipse connection are stored encrypted. Kelwick never holds a person's own mailbox password.
• What you do in the app: what you approved, sent, reverted or asked, and when. This is the audit trail your Admins see in the Timeline.
• Support: what you write to us.

When your workspace connects an ERP or a mailbox, Kelwick reads what that connection allows: customers, products, orders, bids, purchase orders, invoices, stock, vendors, and the emails and attachments in the mailboxes you authorize. Some of this is personal data about your customers, employees and vendors.

We process it only to provide the modules you turn on: to prepare drafts, matches, suggestions and change sets, to answer Ask questions, to run the workflows you configure, and to keep the Timeline. We keep the minimum needed. For example, a mailbox connection reads only the mailboxes your Microsoft 365 admin allows, and never sends or changes anything in them.

• To run the service and show your users what Kelwick prepared.
• To keep the service secure: limiting repeated sign-in attempts, two-step sign-in, enforcing permissions, investigating incidents.
• To support you when you ask.
• To bill you: credits used per item, plan and add-ons.
• To improve the product using aggregate, de-identified measures such as how often a suggestion is accepted. We do not use your Customer Data, or your users' content, to train models.
• To tell Admins about service changes, security notices and billing. Product marketing goes only to people who opted in, and every message has an unsubscribe.

Kelwick uses large language models and other automated systems to read documents, draft text, propose changes and answer questions. These systems produce suggestions; a person in your workspace decides. Kelwick does not make automated decisions with legal or similarly significant effects on individuals.

The models are Anthropic's Claude, run through Amazon Bedrock in US regions (section 6). Under Amazon's terms for Bedrock, what Kelwick sends is not used to train models and is not stored by Bedrock after it returns a result.

• Subprocessors, each processing data only to provide its part of the service, under its terms with us. We give Admins 30 days' notice before adding one.
  • Railway: hosting for the app, its database and this website, in the United States.
  • Amazon Web Services: the AI models (Anthropic's Claude through Amazon Bedrock, in US regions) and sending email (Amazon SES).
  • Twilio: text messages with sign-in codes, only for people who choose texts for two-step sign-in.
• Your own systems: Kelwick changes records in Eclipse only when a person in your workspace does it (sending a bid, applying a change set), under that person's Eclipse username. Email goes from Kelwick's sending address: drafts a person approved, or emails from a workflow your company set to send automatically. Kelwick never sends from or changes your mailboxes.
• Professional advisers and authorities: where the law requires, or to protect our rights, with notice to you where we are allowed to give it.
• A buyer: if Kelwick is sold or merges, data transfers with it under the same commitments, and we tell you first.

We do not sell personal data and do not share it for advertising.

Data is hosted in the United States, with Railway (the app and its database) and Amazon Web Services (the AI models, in US regions). If you are outside the United States, your data is transferred there. For transfers from the UK or EEA: [the safeguards we rely on, to be set with counsel].

• Workspace data: for as long as the workspace exists. Admins can ask us for an export at any time.
• After a workspace is deleted: removed from live systems within 30 days and from backups within 90.
• Timeline: retained with the workspace. Admins can request earlier deletion of specific entries where the law allows.
• People removed from a workspace are deactivated, not deleted, so the Timeline still shows who did what. Their account details are deleted on request where the law allows.
• Billing records: as long as tax law requires, typically seven years.

Depending on where you are you may have the right to access, correct, delete, export or restrict use of your personal data, and to object to some processing. Users can change most account details in Profile. Admins can ask us to export or delete the workspace.

For anything else, write to [privacy email]. We answer within 30 days. If your data is in a customer's workspace, we may direct you to that customer, who controls it, and help them respond.

If you are in the EEA or UK you can complain to your supervisory authority. We would rather hear from you first.

Neither the app nor this website sets cookies. The app keeps your sign-in, and a few display choices, in your browser's local storage. The website has no analytics, and neither runs advertising trackers. There is no cookie banner because there is nothing to consent to.

We protect data with encrypted connections (HTTPS), secrets stored encrypted, permissions by role and department, two-step sign-in, and a Timeline of what Kelwick and your people did. If a breach affects your data we tell your Admins without undue delay and within 72 hours of confirming it.

Kelwick is a business product. We do not knowingly collect data from anyone under 18, and workspaces are opened by companies, not individuals.

We will post changes here and, for material changes, email Admins 30 days ahead. The date at the top tells you when it last changed.

[Kelwick legal entity], [address]. Privacy questions to [privacy email]. Our data protection contact is [name or role].