Privacy Policy

1. Data Controller

The controller responsible for processing personal data is:

2. Scope of this Policy

This Privacy Policy applies to:

• the Entrim website
• the Entrim dashboard
• the Entrim model inference service used with OpenClaw
• account creation, trials, and subscription billing

It explains what personal data we collect, how we use it, and your rights under applicable data protection laws, including the General Data Protection Regulation (GDPR). It does not cover the OpenClaw software itself, which is third-party open-source software you install and run yourself.

4. Prompts and Model Outputs

The Service processes prompts and generated outputs solely to provide the requested inference response to your OpenClaw agents.

Prompts and outputs are not retained by Entrim as stored customer data after request completion.

During inference, prompts and related data may be processed temporarily in memory and may be subject to short-lived caching mechanisms designed to improve inference performance.

These temporary processing mechanisms may include:

• in-memory caching
• limited persistent performance caches used by the inference system

These caches are used only to optimize inference performance and are not used as storage for customer data.

Entrim does not use customer prompts or outputs to train machine learning models.

Customers are responsible for ensuring they have the legal right to process any personal data included in prompts submitted through their OpenClaw agents to the Service.

For personal data contained in prompts and outputs, you (or your organization) act as the data controller and Entrim acts as a data processor, processing such data solely to provide the Service. The remainder of this Privacy Policy describes processing for which Entrim is the data controller, such as account, billing, usage, and website data. If you require a data processing agreement under Article 28 GDPR, contact: info@entrim.ai

6. Legal Basis for Processing

Under the GDPR, we process personal data based on the following legal grounds.

Performance of a Contract

To provide and operate the Entrim services, trials, and subscriptions.

Consent

For marketing communications and analytics cookies. You can withdraw consent at any time.

Legitimate Interests

To maintain service security, prevent abuse, and improve platform reliability.

Legal Obligations

To comply with tax, accounting, and regulatory requirements.

7. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy.

Typical retention periods include:

• account data: for the life of your account and deleted or anonymized within a reasonable period after account closure
• service access logs: up to approximately 90 days
• security logs: up to approximately 30 days
• billing and accounting records: retained as required by applicable tax law

Some data may be retained longer if required by legal obligations or to resolve disputes.

8. Data Sharing

We do not sell personal data.

Personal data may be shared when necessary to operate the platform or comply with legal obligations.

This may include sharing with service providers or when required by applicable law, regulatory authority, or legal process.

9. Service Providers

Entrim uses trusted third-party service providers to operate and support the platform, including:

• Stripe — payment processing
• Google Tag Manager and Google Analytics — website analytics
• infrastructure hosting providers
• email delivery providers for service communications
• marketing and newsletter platforms, where you have subscribed to updates

These providers process personal data only as necessary to perform services on behalf of Entrim and are contractually required to protect such data.

Third-party service providers do not receive or store prompts or model outputs submitted to the Service. Prompts and outputs are processed exclusively within Entrim-controlled inference infrastructure.

10. International Data Transfers

Entrim infrastructure used to process model inference requests is located within the European Union.

However, certain service providers supporting the operation of the platform — such as payment processors, email providers, or analytics providers — may process limited personal data outside the European Union.

Where such transfers occur, Entrim ensures appropriate safeguards are in place in accordance with applicable data protection laws, including the use of standard contractual clauses or equivalent legal protections.

Such transfers relate only to operational data such as account information, billing information, or website analytics, and do not include prompts or model outputs submitted to the Service.

11. Security

We implement technical and organizational measures designed to protect personal data.

Security measures include:

• encrypted communication using HTTPS
• infrastructure access controls
• monitoring of systems and infrastructure
• security protections against abuse and unauthorized access

However, no system can be guaranteed to be completely secure.

12. Your Rights

Under the GDPR you have the following rights:

• the right to access your personal data
• the right to request correction of inaccurate data
• the right to request deletion of personal data
• the right to restrict processing
• the right to data portability
• the right to object to processing
• the right to withdraw consent at any time, where processing is based on consent

To exercise these rights you may contact: info@entrim.ai

We do not use your personal data for solely automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

You also have the right to file a complaint with the relevant supervisory authority.

In Slovenia this authority is:

Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec), Dunajska cesta 22, 1000 Ljubljana, Slovenia — www.ip-rs.si

13. Children's Privacy

The Entrim services are not intended for children.

We do not knowingly collect personal data from individuals under the age of 18.

14. Changes to This Policy

We may update this Privacy Policy from time to time.

When material changes occur we will publish the updated version on our website and, where appropriate, notify you by email or through the dashboard.

15. Contact

If you have questions about this Privacy Policy or how your data is handled, contact: info@entrim.ai