Privacy policy

Pre-launch draft. These policies describe proposed arrangements, not a service operating today. Product behaviour, commercial terms, company details and legal review remain pending. They do not take effect until launch.

This page explains, in plain words, what personal data we handle when you use our website, try our assistant or use our service, and what your rights are.

Who we are

NuTea Limited, trading as Punjabi Labs (“we”, “us”), is a company registered in Ireland, company number [company number, to be added]. Our registered office is [registered office address, to be added].

You can contact us about anything in this policy at contact@punjabilabs.com. We have not appointed a data protection officer, and that address is the right place for privacy questions and requests.

We are the “controller” of the personal data described on this page, except in the situation described in the next section.

What this policy covers

This policy covers personal data of:

people who visit this website;
people who try our public demo assistant;
people who start a free trial or hold an account with us (our customers and their staff);
people who write to us.

It does not cover conversations on a customer’s own website. When a business puts our assistant on its website, that business decides why and how its visitors’ data is used, and we handle that data on the business’s behalf as its “processor”, under our data processing terms. The business’s own privacy notice applies to those conversations, and you should ask that business about them.

What we collect, why, and on what basis

The table shows each situation separately. We collect only what we need for the purpose shown.

When	What we handle	Why	Legal basis
You browse this website	Technical data your browser sends: IP address, browser and device type, pages requested, date and time. Our hosting provider keeps this in server logs. We do not use analytics or advertising trackers. The redesigned theme uses device fonts and does not request Google Fonts (see the cookie policy).	To deliver the site and keep it secure.	Legitimate interests (running and securing the site).
You talk or type to our demo assistant	What you say (live audio) and type, the language, the length and outcome of the conversation, and usage counts tied to your connection so we can enforce fair limits. We do not record or store audio.	To answer you, to keep the demo free within fair limits, and to prevent abuse.	Your consent (you choose to start the conversation and allow the microphone); legitimate interests for limits and abuse prevention.
You start a free trial or open an account	Name, email address, a password (stored only in scrambled form) or a sign-in link, business name, website address, country, chosen plan, notification settings, and usage such as minutes used.	To create and run your account and deliver the service.	Contract (or steps you ask for before a contract).
You pay us	Billing name, address, VAT number and payment details. Card details go directly to our payment provider; we never see your full card number.	To take payment and issue invoices.	Contract; legal obligation (tax records).
You write to us	Your message, your email address and anything you choose to include.	To reply and keep a record of the conversation.	Legitimate interests; contract where you are a customer.
You ask to hear from us (for example, to be told when trials open)	Your email address and any details you give us.	To send you what you asked for. You can unsubscribe at any time.	Your consent.

We do not sell personal data, and we do not use it for advertising.

Voice and artificial intelligence

Our assistant is an AI. It says so at the start of every conversation, and it asks before your browser opens the microphone. You can stop at any time and use typing instead.

When you speak, your audio travels from your browser to Google’s Gemini service, which turns it into the assistant’s reply. We use Google’s paid service, under terms in which Google acts as our processor and does not use your prompts or responses to improve its own products. Google keeps prompts and responses for a limited time only to detect misuse and to meet legal duties. We do not record or store your audio.

The assistant does not make decisions about you that have legal or similarly significant effects. Please do not tell the demo assistant anything sensitive, such as health details, payment card numbers or passwords.

Transfers outside the European Economic Area

Some of our providers, such as Google and Stripe, may process data outside the European Economic Area, including in the United States. When that happens we rely on an adequacy decision (for example, the EU–US Data Privacy Framework) or on the European Commission’s standard contractual clauses, together with the safeguards our providers describe in their own terms.

How long we keep it

Data	How long
Website server logs	For as long as our hosting provider keeps them, normally a few weeks.
Demo conversation records (length, time, language, outcome, usage counts)	Up to 30 days, then deleted or made anonymous.
Account details	While your account is open and for up to 30 days after you close it.
Enquiries and call logs collected for a customer	As set by the customer, and deleted within 30 days after the account is closed.
Invoices and payment records	Six years, as Irish tax law requires.
Messages you send us	Up to two years after the conversation ends.
Your email for updates you asked for	Until you unsubscribe.

We keep data for a shorter time when it is no longer needed, and for longer only where the law requires it.

Your rights

Under data protection law you have the right to:

ask for a copy of the personal data we hold about you;
have wrong data corrected, and have data deleted in the cases the law provides for;
ask us to restrict how we use your data, or object to uses based on our legitimate interests;
receive data you gave us in a portable format, where the law provides for it;
withdraw your consent at any time, where we rely on consent. This does not affect what we did before.

To use any of these rights, write to contact@punjabilabs.com. We may need to check who you are first. We will reply without undue delay and in any case within one month, as the law requires.

If you are unhappy with how we handle your data, you can complain to the Irish Data Protection Commission (dataprotection.ie, 21 Fitzwilliam Square South, Dublin 2, D02 RD28). We would appreciate the chance to put things right first.

If your data was collected by a business using our assistant on its own website, please contact that business first. If you tell us, we will help pass your request to them.

How we protect data

Connections to our site and service are encrypted. Our secret keys stay on our servers and are never sent to your browser. Each assistant can be used only on the website of the business that set it up, and usage limits stop abuse. Access to customer data is limited to the people who need it. No system is perfectly secure, and if a breach affecting you occurs we will tell you and the regulator as the law requires.

Children

Our service is for businesses, not for children, and we do not knowingly collect children’s personal data. If you believe a child has given us personal data, write to contact@punjabilabs.com and we will delete it.

Changes to this policy

If we change this policy in a way that matters, we will change the date at the top of this page and, for customers, tell you by email before the change takes effect.