Privacy Policy

1. Who processes the data

The operator of the Termio service (website, API and mobile apps) is:

For privacy questions, write to support@smartopol.com.

2. What Termio is

Termio is B2B software for salons and similar service businesses: appointment booking, clients, team, services, notifications and a built-in AI Agent. The salon owner creates the account; team members and the salon's client data are entered within that account.

3. What data we process

Depending on how you use the service, we may process:

• Account and access: name, email, magic link or sign-in with Google / Apple, role (owner, admin, team member), session / token.
• Salon data: name, time zone, settings, working hours, services, prices, resources.
• Team: name, calendar color, schedule, time off, and contact details if you enter them.
• Salon clients: name, phone, email, notes, appointment and spending history. The salon enters this data; we process it as a processor on the salon's behalf.
• Appointments and operations: time, services, status, notes, waitlist, and expenses if you record them.
• AI Agent: the content of chat messages and the business context the Agent reads or writes (for example appointments, clients). We store messages in your account to keep the conversation history.
• Media: photos or video you upload (for example attached to a client). Files are stored on servers in the European Union.
• Device and notifications: push token, device type, language. When the mobile app crashes or throws an unhandled error, we also send crash / diagnostic data (stack trace, app version, phone model) linked to the team member ID and the salon ID. We do not send names, emails or phone numbers of clients, or screenshots.
• Subscription billing: subscription status, plan, reference IDs at the payment processor. Card data is processed by the payment processor; we do not store the full card number.
• Technical data: IP address, request time, browser type / app build, to the extent needed for security and operation of the service.

4. Why we process data

• providing and maintaining the Termio service (account, calendar, CRM, sync between web and mobile app);
• AI assistance in running the salon, based on your requests and permission settings;
• notifications (push, email, SMS flows that you start or enable);
• subscription billing and fraud prevention;
• security, diagnostics, and compliance with legal obligations.

We do not sell personal data to third parties. We do not use salon clients' data for third-party advertising.

5. Legal basis (where GDPR or similar laws apply)

• Performance of a contract with the salon owner (providing the SaaS service).
• Legitimate interest (security, fraud prevention, basic reliability analytics).
• Legal obligation (for example tax / accounting records of the subscription, where applicable).
• Where consent is required (for example certain marketing messages), we ask for it separately and you can withdraw it.

For data about the salon's end clients, the salon owner is typically the controller, and Smartopol, LLC the processor, acting on the salon's instructions and this policy.

6. Who we share data with

We share data only with providers needed for Termio to work, under data processing agreements where applicable:

• Hosting and infrastructure. Application and database hosting. The database is in the European Union.
• Authentication and email flows tied to the account (sign-in, verification, reset).
• AI Agent (in the app: Termio). When the owner uses the AI agent, the question and that salon's business context (for example appointments, clients, team, notes when needed) are processed in the United States. The path: first OpenRouter (request routing), then Relace (model execution). We store the conversation history on Termio servers. These providers do not use the content to train models. In the mobile app, the AI agent asks for explicit permission before sending anything for the first time; the permission can be revoked in Settings, and the AI agent then stops sending data from the phone until it is granted again.
• Push notifications. The token goes through platform channels (Apple, Google) so a reminder reaches the device.
• Media. Uploaded files (photos, video) are stored on servers in the European Union.
• Subscription billing (Creem and related payment processors) for checkout and subscription status.
• Mobile app stability (Sentry). Functional Software GmbH, EU region (de.sentry.io). Crash and diagnostic data from the phone go there, linked to the team member ID and the salon ID, so we can fix the crash. No Session Replay. This processor does not store IP addresses.

We may disclose data if required by law or a court order, or to protect the rights and safety of users or our property. In the event of a merger or sale of the business, data may pass to the successor subject to an appropriate privacy obligation.

7. International transfers

The operator is registered in the United States. The primary database is in the European Union. Media is stored on servers in the European Union. Mobile app crash reports (Sentry) stay in the EU region. AI processing (OpenRouter and Relace) takes place in the United States. Other subprocessors (for example app hosting, push, billing) may process data in the EU, the US or other countries. Where required, we rely on appropriate transfer mechanisms (for example standard contractual clauses) and safeguards at our subprocessors.

8. How long we keep data

• Data of an active salon (including AI chat history) is kept while the account exists and while it is needed for the service.
• Soft-deleted records (for example team members, clients) may remain in the system temporarily for recovery and integrity, and are then removed according to internal timelines.
• Closing a salon / deleting an account: we delete or anonymize data within a reasonable time, except where the law requires longer retention (for example billing).
• Logs and security records: shorter periods, except for an incident that requires longer retention.

9. Security

We use HTTPS, per-salon access control (multi-tenant), authentication and technical measures on our infrastructure. No system is 100% risk-free; report a suspected incident to support@smartopol.com.

10. Your rights

Depending on your jurisdiction, you may have the right to:

• request access to, correction of, or deletion of your data;
• request a copy of your data (export) where applicable;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent.

Send requests to support@smartopol.com. If you are a team member or client of a salon (not the account owner), contact the salon owner first; we can help the salon fulfill the request.

You have the right to lodge a complaint with the supervisory authority in your country (in the EU: your local DPA; in Serbia: the Commissioner for Information of Public Importance and Personal Data Protection).

11. Children and minors

Termio is a business (B2B) product. It is not intended for children under 16. We do not knowingly collect data from minors for use of the service.

12. Mobile apps and app stores

The same rules apply to Termio on the web and on Android / iOS (and related builds). The Google Play and App Store listings name this URL as the privacy policy. We ask for device permissions (for example notifications, or the camera if used for media) only when they are needed for a feature you start.

13. Cookies and similar technologies

On the web we use necessary cookies / local storage for the session, preferences (for example theme) and security. We do not place third-party advertising trackers as part of the core service. If we add further analytics, we will update this policy.

14. Changes

We may update this policy. The date at the top of the page shows the last change. We may announce significant changes in the app or by email to account owners. Continuing to use the service after changes means you accept the updated version, except where the law requires otherwise.

15. Contact

Smartopol, LLC · Termio
Email: support@smartopol.com
Address: 1111B S Governors Ave, Ste 97389, Dover, DE 19904, USA