Privacy Policy

Effective 4 September 2026 · Version 1.0 · English (Dutch translation available on request)

1. Who is responsible (Controller)

peggoo B.V. [registered company name]
[registered address], The Netherlands
Chamber of Commerce (KvK): [KvK number] · VAT: [BTW number]
Privacy contact: privacy@peggoo.com

peggoo B.V. is the controller for personal data processed through peggoo.com (the "Service"). We do not have a designated Data Protection Officer; contact us at the address above for any privacy matter.

2. What data we process and why

DataPurposeLegal basis (GDPR)
Email address, hashed password, account settingsCreating and managing your account, authenticationArt. 6(1)(b) — contract
Conversations and messagesProviding the AI chat, agent and coding features you requestArt. 6(1)(b) — contract
Distilled long-term memoriesPersonalising responses across conversations (you can view, edit and delete memories at any time)Art. 6(1)(b) — contract
Uploaded files and workspace contentFile analysis, coding-agent tasks, previews — stored in your per-conversation workspaceArt. 6(1)(b) — contract
Usage records (model, tokens, cost, timestamps)Quota enforcement, billing accuracy, abuse preventionArt. 6(1)(b) contract / Art. 6(1)(f) legitimate interest
IP address and request logsRate limiting, security monitoring, fault diagnosisArt. 6(1)(f) — legitimate interest (service security)
Billing status and payment metadataSubscription management (card details are processed only by Stripe — we never see or store them)Art. 6(1)(b) contract / Art. 6(1)(c) legal obligation
Referral and affiliate recordsAdministering the referral and affiliate programmes you participate inArt. 6(1)(b) — contract / programme terms

We do not use your content or personal data for advertising, profiling, or automated decision-making with legal effect.

3. How AI features process your data

To generate responses, your messages (and relevant conversation context) are sent to our AI model provider, Zhipu AI (BigModel), acting as our processor. Content is transmitted solely to provide the service you requested. We do not use your conversations to train our own models. Retention by the provider is governed by their API terms; see §6 for transfer safeguards.

Distilled memories are derived from your conversations on your behalf. You can review everything peggoo remembers via Settings → Memory, and delete any item or all memories at any time.

4. How long we keep data

DataRetention
Account and billing recordsLifetime of the account; billing records up to 7 years (tax law)
Conversations, memories, workspacesUntil you delete them (in-product) or delete your account
Deleted-account data in encrypted backupsMaximum 14 days, then purged
Security and request logs90 days

Deleting your account (Settings → Danger zone) erases your profile, conversations, memories and workspaces. The GDPR data export in Settings gives you a machine-readable copy first.

5. Who we share data with (Processors)

ProcessorRoleLocation
Zhipu AI (BigModel)AI model inference for chat/agent featuresChina (see §6)
Stripe Payments Europe B.V.Payment processing (card data never reaches us)Netherlands / Ireland
Self-operated infrastructureApplication, database, object storageNetherlands

All storage and databases run on our own infrastructure in the Netherlands. We do not sell or rent personal data to anyone.

6. International data transfers

Because our primary AI model provider operates in China, messages you send are transferred outside the EEA. This transfer is safeguarded by the European Commission's Standard Contractual Clauses with the provider and supplementary technical measures (transmission over TLS, processing only to fulfil your request). If you prefer not to have content processed outside the EEA, do not send it via chat; core storage remains in the Netherlands.

7. Your rights

Under the GDPR you have the right to:

Exercise any right by writing to privacy@peggoo.com or using the in-product tools. We respond within 30 days.

8. Security

9. Children

The Service is not intended for anyone under 16 (Art. 8 GDPR / Dutch implementation). We do not knowingly process children's data; contact us if you believe a minor created an account and we will remove it.

10. Changes to this policy

We may update this policy to reflect changes in the Service or law. Material changes are announced in-app at least 14 days before taking effect. This version: 4 September 2026.