This policy explains what the Viroen chat assistant collects when you talk to it, why, who sees it, and what you can ask us to do about it. Questions or requests: hello@viroen.cc.
1. Who we are
Viroen (viroen.cc) makes an AI chat assistant that financial firms add to their websites. It answers visitors' questions and passes their inquiries to the firm. Viroen is a software provider. We are not a financial adviser, broker or registered investment adviser, and we don't give investment, tax or legal advice.
Who is responsible for your data depends on where you chat:
- On a firm's website. The firm is responsible for your personal data (it is the “controller”, or the “business” under California law). Viroen processes the data on the firm's behalf and under its instructions (as its “processor” or “service provider”). The firm's own privacy policy also applies, including to what it does with your details after we send them to it, and to the rest of its website.
- On viroen.cc, including our demos. Viroen is responsible for your data.
2. What we collect
- Your chat messages. Everything you type into the chat and the assistant's replies. We save the full conversation.
- What you choose to tell the assistant. To connect you with the right person, the assistant asks what prompted you to get in touch, your general situation (for example employed, retired or a business owner), roughly how much you have to invest, whether you already work with an adviser, your timeline, when you would like to talk, and your name and email. You can skip any question. If you share a phone number, we collect that too.
- A hashed IP address. We turn your IP address into a keyed one-way hash and store only the hash, never the IP address itself. We use it to limit how many conversations one visitor can start.
- Basic technical data. The address of the web page where you opened the chat, the language of the chat, and when the conversation started and was last active. Like any website, our hosting provider also receives standard request information (such as your IP address and browser type) to deliver the page.
The chat doesn't use cookies, and viroen.cc doesn't use analytics or advertising trackers. The chat doesn't remember you on your device: reloading the page starts a new conversation. A firm's own website may use cookies; its privacy policy covers those.
We don't ask for account numbers, passwords, government ID numbers or card details. Please don't share them in the chat. If you're an existing client with a question about your account, contact your adviser or the firm directly.
3. Why we use it
- To answer your questions and keep the conversation going.
- To pass your details to the firm you contacted. When you share an email address or phone number, we use AI to summarize the conversation and email that summary, with the full transcript, to the firm. The summary includes a rough priority label (hot, warm or cold) to help the firm decide whom to call first. The label doesn't decide anything about you; people at the firm decide whether and how to follow up.
- To alert the firm. If you ask for a person, make a complaint, ask about an existing account, or seem upset, we email the conversation to the firm right away, even if you haven't left contact details.
- To keep a record. We keep conversations so the firm can review them and meet its own recordkeeping obligations. We can give the firm an export of its conversations.
- To prevent abuse and spam. We limit message length, messages per conversation and conversations per visitor, using the hashed IP address. Every reply is also checked automatically before it's sent, to stop the assistant giving financial advice or breaking the firm's rules.
We don't use your data for advertising.
4. Who we share it with
- The firm you contacted, through the email alerts and exports described above.
- Our service providers that run the app, only for that purpose:
- Anthropic: the AI model that writes and checks replies and summarizes conversations.
- Supabase: stores conversations.
- Resend: sends the email alerts to the firm.
- Cal.com: where a firm lets you book a call in the chat, it books the time you choose and emails you the confirmation. It receives your name, email address and time zone.
- Vercel: hosts the website and the chat.
- Authorities, if the law requires us to.
We never sell or rent personal data, and we don't share it with anyone for advertising.
5. International transfers
Conversations are stored in the United States, in Supabase's East US (North Virginia) region. Our other service providers (Anthropic, Resend and Vercel) also process data in the United States, and may process it in other countries where they operate. Privacy laws there may differ from those where you live.
6. How long we keep it
We keep conversations (and the hashed IP address stored with them) while the firm uses Viroen. We delete them within 30 days of a verified deletion request or of the end of the firm's contract, unless the firm must keep them for its own legal recordkeeping. Demo conversations on viroen.cc are deleted within 30 days of a verified request.
Emails already sent to a firm are held in the firm's own inbox, under the firm's own policy.
7. Security
We take reasonable measures to protect your data. Stored conversations can only be read by our server and by authorized Viroen staff through a password-protected tool; the database blocks all public access; IP addresses are stored only as a hash; and data travels over encrypted connections. No system is 100% secure, so we can't guarantee absolute security.
8. Your rights
Depending on where you live, you can ask to access, correct or delete your personal data, or object to how it's used. To ask, email hello@viroen.cc. Tell us the website where you chatted and roughly when, so we can find the conversation. We may ask you to confirm details from the conversation to check it's yours.
When a firm is responsible for the data, we may pass your request to that firm and help it respond. You can also contact the firm directly. We won't treat you differently for exercising your rights.
California (CCPA / CPRA)
California residents have the right to know what personal information is collected about them, and to delete and correct it. In the last 12 months, the categories we collected are the ones in section 2: identifiers (name, email, phone number, hashed IP address), financial information you choose to share (such as roughly how much you have to invest), internet activity (the page where you chatted) and inferences (the priority label). We collect it for the purposes in section 3 and disclose it only as in section 4. We don't sell or share personal information (including for cross-context behavioral advertising). You can use an authorized agent to make a request.
Australia (Privacy Act 1988)
We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. You can ask to access or correct your information. As section 5 explains, it may be disclosed to service providers in the United States. If you have a complaint, email us first and we'll aim to respond within 30 days. If you're not satisfied, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
Chile (Ley 19.628 and Ley 21.719)
We handle personal data in line with Ley 19.628 on the protection of private life and Ley 21.719, which updates it. You can ask to access, correct, delete or block your data, object to its use, and ask for a copy of it. If you're not satisfied with our answer, you can complain to the Agencia de Protección de Datos Personales created by Ley 21.719.
9. Under-18s
The chat is not for anyone under 18, and we don't knowingly collect data from people under 18. If you think a minor has used it, email us and we'll delete the conversation.
10. You're talking to an AI
The chat assistant is an AI, not a person. Its replies are written by an AI model (Anthropic's Claude) and checked automatically before you see them. People at the firm may read the conversation later to follow up with you. The assistant can make mistakes; see our Terms of Use.
11. Changes to this policy
We'll post any changes on this page and update the “Last updated” date at the top. If a change is significant, we'll say so clearly here.
Contact
Viroen · hello@viroen.cc