Privacy Policy

Welcome to Deskbolt, a platform developed and operated by MEDIASWAPP SL ("Deskbolt", "we", "us", or "our").

We are committed to protecting your privacy and being transparent about how we collect, use, and safeguard your personal data. This Privacy Policy explains our practices in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and other applicable data protection laws.

By using Deskbolt or interacting with any part of our platform (live chat, WhatsApp, CRM integrations, or our website), you agree to this Privacy Policy.

Legal Entity: MEDIASWAPP SL

VAT: ESB65967713

Address: Calle Hermosilla 48, 1-DR, 28001 Madrid, Spain

Website: https://www.deskbolt.com

Email: data@deskbolt.com

Data Protection Officer: Karim Bensfia – karim@deskbolt.com

This Privacy Policy applies to all Deskbolt interactions, including:

• Visitors to our website
• Clients using our SaaS platform
• End users engaging with our clients via Deskbolt-powered chat or WhatsApp integrations

Depending on context, Deskbolt acts as:

We collect information directly from users, automatically through our systems, and via third-party integrations.

Data may be collected through:

We process personal data for the following legitimate business purposes:

We never sell personal data.

• ✓
  Performance of a contract – providing Deskbolt's services to clients
• ✓
  Legitimate interest – maintaining and improving our services
• ✓
  Consent – for analytics and marketing tracking
• ✓
  Legal obligation – compliance with applicable laws and regulations

Deskbolt uses AI and automation to:

• Identify and score lead temperature
• Personalize communication sequences
• Recommend follow-up actions for agents

Deskbolt clients (real estate agencies) are responsible for:

• Obtaining consent from their leads and visitors before using Deskbolt
• Informing end users that conversations may be processed by AI
• Managing deletion or modification requests from their users

Deskbolt processes client data strictly under their instructions and agreements (DPA).

Our production infrastructure is located in the United States (Google Cloud Platform for application hosting, Amazon Web Services via Neon for database hosting). Several of our subprocessors are also established outside the EEA.

For all transfers of personal data from the EEA, the UK or Switzerland to the United States or other third countries, Deskbolt relies on the following lawful transfer mechanisms under Chapter V of the GDPR:

• Standard Contractual Clauses (2021 version) approved by the European Commission (Commission Implementing Decision (EU) 2021/914 of 4 June 2021);
• EU–US Data Privacy Framework (Adequacy Decision (EU) 2023/1795 of 10 July 2023), where our subprocessors are certified to it;
• For UK customers, the UK Addendum to the SCCs issued by the ICO;
• For Swiss customers, the Swiss SCCs;
• Encryption in transit (TLS 1.3) and at rest (AES-256), strict access controls, and data minimization.

Further detail is available in our Data Processing Agreement (sections 6 and 11).

Deskbolt uses AI to:

• Analyze chat content and extract key insights
• Generate "Smart Data" summaries
• Craft automated follow-up messages

AI processing partners include OpenAI, Anthropic (Claude), and Google (Gemini). All data shared with these providers is handled under strict confidentiality, encryption, and legal compliance.

Deskbolt partners with vetted subprocessors to deliver its services.

Core subprocessors include:

A detailed and up-to-date list of subprocessors — including their location and applicable legal safeguards (SCCs 2021, EU–US DPF, etc.) — is available in section 6 of our Data Processing Agreement. Some subprocessors may process data independently under their own privacy policies.

You have the right to:

If you are a U.S. resident (including California), you have the right to:

• Know what personal data is collected and used
• Request deletion of your data
• Request access to your information
• Opt out of the sale or sharing of personal data (Deskbolt does not sell data)
• Equal treatment for exercising your rights

We use cookies and similar technologies for:

• Website functionality
• Analytics and product improvement
• Marketing attribution

You can manage your preferences via your browser or our Cookie Consent Banner.

We apply differentiated retention periods depending on the nature of the data, in line with the GDPR principles of data minimization and storage limitation:

• Lead and conversation data — up to three (3) years after the last meaningful interaction (legitimate interest: B2B prospection and service continuity).
• Client account and contractual data — up to five (5) years (legal obligation: Spanish tax and accounting compliance).
• Backups and system logs — up to thirty (30) days (security, continuity, audit trail).

These periods may be shortened if you delete your account, withdraw consent, or exercise your right to erasure. Anonymized data may be retained for statistical or security purposes.

By subscribing or providing your contact details, you agree to receive relevant Deskbolt communications. You can unsubscribe at any time using the link in our emails or by contacting data@deskbolt.com.

With prior consent, Deskbolt may use client names, testimonials, and logos for marketing materials, case studies, and presentations, in accordance with each client's brand guidelines.

Deskbolt does not knowingly collect or process personal data of individuals under the age of 16. If such data is discovered, it will be promptly deleted.

In the event of a merger, acquisition, or sale of assets, user data may be transferred as part of that transaction, subject to this Privacy Policy.

If you believe your data has been mishandled, you may:

• Contact us directly at data@deskbolt.com
• File a complaint with the Spanish Data Protection Agency (AEPD) or your local authority

We will respond to all privacy-related complaints promptly and fairly.

Our platform may contain links or integrations with external services (e.g., CRMs, APIs, or payment providers). Deskbolt is not responsible for their content or privacy practices. We recommend reviewing their privacy policies when using such services.

IP geolocation data — used to identify the legal jurisdiction applicable to each visitor (EU vs. United States, US state-level consent laws) — is provided by DB-IP under the Creative Commons Attribution 4.0 International License.

We may update this Privacy Policy periodically. Significant changes will be communicated via email or dashboard notification.

The latest version is always available at: https://www.deskbolt.com/privacy-policy

Deskbolt (MEDIASWAPP SL)

Attn: Data Protection Officer

Calle Hermosilla 48, 1-DR

28001 Madrid, Spain

Email: data@deskbolt.com