Privacy policy

The Remote Conversation Navigator (“the Navigator”) is operated by MB CE Europa, based in Lithuania, European Union. The product is published under the “Ironwell & Co” brand, with MB CE Europa as the registered legal entity behind it. For anything in this policy, including data requests, write to iron@ironwellco.com .

• Your conversations, notes, recaps, checklists and call history are stored locally in your browser (IndexedDB). They are never uploaded to us.
• The Navigator never records, listens to, or transcribes any call. It has no access to your microphone, camera, screen or meeting software.
• We do not run advertising, tracking pixels, session recording, or third-party analytics.

Everything you create while using a route stays in your browser’s local database: call titles, the five context answers, the answers you pick at each stage, quick notes, evidence, generated recaps, follow-up reminders, personality read results, and app settings. Your licence key, the email you activated with, and a random device identifier are also kept locally so the app can re-check your licence.

Because there is no server copy, clearing your browser data, using private browsing, or uninstalling the app deletes those calls permanently and irreversibly. We cannot restore them. Use the export/backup function if you want a copy you control.

1. Licence activation and re-check

When you activate or the app periodically re-checks your licence, we receive your licence key, the email address you activate with, and a randomly generated device identifier (plus a short device label such as the browser and platform name). We store these to enforce the three-device limit and to bind a key to the buyer’s email so keys cannot be shared. This data is not used for marketing.

2. Anonymous situation samples

The free-text description you type at the start of intake (“what is this conversation about?”) is stored as an anonymous sample. It is saved with no user account, no email, no licence key, no device identifier and no IP-based profile attached and cannot be linked back to you or your licence. We read these samples only to decide which routes should exist and how the classifier should behave. Please avoid typing names, employer names or other identifying details into that field.

3. Anonymous product event counts

We record anonymous counts of a few product events — such as starting the free demo, finishing it, or clicking a purchase button — with no identifier of any kind linking them to you, your device or your licence, used only to see which steps of the free demo people complete.

4. AI personalisation and AI recap drafting

If you use the AI brief or AI recap features, the relevant context for that request (the scenario, your context answers and the notes needed to draft the output) is sent to our AI provider to generate the result. It is used to produce your output and is not used to build a profile of you. All other AI-free parts of the product work offline.

5. Hosting and technical logs

Our hosting and backend providers process standard technical request data (such as IP address and timestamps) to deliver and secure the service.

• Performance of a contract (Art. 6(1)(b)) — licence key, email and device identifier, to deliver the licence you bought and enforce its terms; sending context to the AI provider when you request an AI output.
• Legitimate interests (Art. 6(1)(f)) — anonymous situation samples to improve the product, and security/abuse prevention. As these samples carry no identifiers, they are not personal data once stored.
• Legal obligation (Art. 6(1)(c)) — retaining purchase records where tax or accounting law requires it.

• Licence records and device slots: for as long as the licence exists.
• Anonymous situation samples: kept indefinitely, as they contain no identifiers.
• AI requests: processed to return your result; retained by the AI provider only as long as needed for abuse prevention under their terms.
• Local data on your device: until you delete it — it is entirely under your control.

You have the right to access, correct, delete, restrict or object to the processing of your personal data, to data portability, and to lodge a complaint with the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija) or your local supervisory authority.

To exercise any of these, email iron@ironwellco.com from the address your licence is registered to. We will respond within 30 days. Note that deleting your licence record deactivates the licence on all devices, and that we cannot retrieve, correct or delete the anonymous situation samples individually, because nothing links them to you.

We do not sell your data. We share it only with the processors needed to run the service: our hosting/backend provider and our AI provider. Where a provider processes data outside the EEA, the transfer relies on the European Commission’s Standard Contractual Clauses or an adequacy decision.

The Navigator is not intended for use by anyone under 16.

If we change this policy we will update the date above and, for material changes, note it in the app.