Privacy Policy

1. Who we are

Fayla ("Fayla", "we", "us") is a Chrome extension and companion backend service that connects to the sources you choose — Gmail today, with more on the way — identifies conversations with customers who are going quiet, and prompts you to follow up. Fayla is operated by Antreprenor Independent Ivan Balan (IDNO 1026023125716), a self-employed independent entrepreneur registered in Chișinău, Republic of Moldova, who is the data controller for the personal data described in this policy. You can reach a human at hello@fayla.io.

This policy covers the Fayla Chrome extension, the Fayla backend API, and this website.

2. What data we collect

Account and sign-in data

When you create a Fayla account we store your email address, and — if you signed up with a password rather than a social sign-in — a bcrypt hash of that password. We never store your password itself. We also store an email-verification token while activation is pending, account timestamps, and a record that you acknowledged this policy when the account was created (the date, and which revision of the policy was in force).

Fayla offers two social sign-in options, "Continue with Google" and "Continue with Facebook". Both work the same way: the provider hands the extension a token, our backend asks the provider directly who that token belongs to, and we store the resulting identity link — which provider it was, that provider's own account identifier for you, and the email address the provider vouched for. Where the provider also supplies your name, we store that. We do not receive or store a password from either provider, and we do not receive your friends, contacts, posts, or any other profile content: the only permissions Fayla asks either provider for are your basic profile and your email address.

Signing in with Google or Facebook gives Fayla no access to your mailbox. Connecting a mailbox is a separate, explicit step (see section 3).

Subscription and billing data

We store your plan ("free" or "individual"), your subscription status, your trial end date, the end of your current paid period, and the customer and subscription identifiers issued by our payment provider. We never see or store your card number. Payment details are collected and held entirely by Lemon Squeezy on their own hosted checkout page (see Third parties).

Connected source data

For each source you connect we store the channel type (Gmail is the only source available today — see section 3), the account address or identifier on that source, a display name, and internal sync bookkeeping so we know where a previous sync stopped.

Conversation data

This is the sensitive part, so here is the precise list. For each conversation Fayla surfaces, we store in our database:

• the source's own thread and message identifiers, and the conversation's subject line where one exists;
• the name and address (email, or the source's equivalent) of the other participant in the conversation;
• the date of the last message and whether it was sent by you or by them;
• the source's own short snippet (the one-line preview) of the most recent message, where the source provides one;
• facts extracted from the conversation by our AI: customer name, any price or deadline mentioned, the service discussed, apparent sentiment and interest, commitments you made to them, the stage of the conversation, and who owes the next reply;
• the resulting priority score, queue bucket (Today / Tomorrow / Later / Cooling), and the reason it was surfaced;
• your own actions on the conversation: snoozes, dismissals, and dismissal reasons.

We do not store copies of your full messages or your attachments. Message bodies are fetched from the connected source while a sync is running, truncated (currently to the first 4,000 characters of each message), passed through our AI provider for analysis, and then discarded — they are held in memory for the length of that request and are never written to our database. What persists is the derived summary described above, plus the source's own snippet. Attachments are never fetched at all.

AI usage records

Each AI call we make on your behalf writes a usage record: your user ID, which feature triggered it (triage, classification, or reply drafting), the provider and model used, token counts, and internal rate-limiting bookkeeping (how many other accounts were competing for capacity at that moment). This exists to meter plan limits and to keep one busy account from starving another. It contains no message content and no information about who you were emailing.

What we do not collect

Fayla has no analytics SDK, no advertising pixel, no session-replay tool, and no third-party error-tracking service in either the extension or this website. We do not build advertising profiles and we do not track you across other sites.

3. The Google permissions we request, and why

Gmail is the only source Fayla can connect today, so this section is Google-specific. When another source ships, connecting it will disclose that source's own permissions here, the same way and before it becomes available — never bundled into this section after the fact.

Fayla requests the narrowest set of Google OAuth scopes that lets the product work. Each one maps to a specific feature; if we stopped using a feature we would drop the scope.

Signing in to Fayla is deliberately kept separate from all of this. "Continue with Google" uses a different Google client that requests only openid, email and profile. "Continue with Facebook" requests only public_profile and email. Neither grants Fayla any access to your mail, and Facebook sign-in grants no access to your Facebook messages, friends, posts, or pages. Creating an account and connecting a mailbox are two distinct, explicit steps.

4. How we use your data

We use the data described above only to:

• identify which conversations need a follow-up and rank them into your queue;
• filter out newsletters, receipts and automated mail so they never reach the queue;
• generate a suggested reply when you ask for one, and save it back to the connected source (a Gmail draft today);
• authenticate you and keep you signed in;
• apply your plan's limits and process your subscription;
• send transactional email — account activation and account-related notices;
• keep the service running, debug failures, and prevent abuse;
• comply with the law where we are legally required to.

We do not sell your data. We do not share it with advertisers or data brokers. We do not use your email content to train AI models, and we do not use it for any purpose other than providing the features you can see in the product.

We do not use your email content for human review except where you explicitly send it to us in a support request, or where the law requires it.

5. Google API Services Limited Use disclosure

In practice this means Google user data obtained through the scopes above is used only to provide or improve user-facing features that are prominent in Fayla, is not transferred to others except as necessary to provide those features, to comply with applicable law, or as part of a merger or acquisition, is never used or transferred for serving advertisements, and is never read by humans except with your explicit consent, for security purposes, to comply with applicable law, or where the data has been aggregated and anonymised.

Content from your connected sources (Gmail today) is transferred to exactly one class of third party in normal operation: the AI provider that performs the analysis and drafting, described below. It is not transferred anywhere else.

6. Where your data lives and how it is protected

Your connected-source access token is not stored on our servers

This is deliberate and worth stating plainly. The OAuth token that grants access to a connected source (Gmail today) is held by the Chrome extension in your browser's local extension storage (chrome.storage.local) and is sent to our backend with each individual request, used for that request, and not persisted. Fayla's servers hold no standing credential to your connected source. If you uninstall the extension or revoke access with that source's own provider (for Gmail, your Google Account), our backend cannot reach anything there at all — regardless of what is still in our database.

The rest

• Fayla currently holds no standing credential of any kind to any of your accounts. The database has a dedicated encrypted column reserved for the connection credentials that future non-email channels will need, protected with AES-256-GCM; today nothing writes to it, because Gmail is the only channel Fayla supports and its token lives in your browser.
• Your account, subscription and derived conversation data is stored in a hosted PostgreSQL database in the European Union.
• The backend API is hosted in the European Union (Frankfurt). All traffic between the extension, our API, Google and our providers runs over TLS.
• Sessions are signed JSON Web Tokens with a limited lifetime. Passwords, where they exist, are stored only as bcrypt hashes.
• Every database query is scoped to your own user record, so one account cannot read or delete another account's data by guessing an identifier.
• Plan limits and access checks are enforced on the server, not in the extension UI.

No system is perfectly secure, and we will not claim otherwise. We aim to keep the amount of your data that exists on our side small enough that a breach would be survivable — which is the main reason we store derived summaries rather than your mail.

7. Third parties and subprocessors

These are every external service that can receive your data as part of Fayla working normally. There are no others, and there are no advertising or analytics providers on this list. Gmail is the only connected-source provider today; as we add sources, this table grows with them before they ship, never silently.

We will update this list before adding any new provider that can access your data.

8. Retention, revoking access, and deletion

Cutting off access

You can revoke Fayla's access to a connected source at any time from that source's own provider — for Gmail today, that's your Google Account's third-party access page — or by disconnecting the account inside the extension, which revokes the token with the provider directly. Uninstalling the extension also removes the stored token from your browser. Once access is revoked, Fayla cannot read anything further from that source.

Deleting what we have stored

The extension's settings screen includes a "delete my data" action that permanently removes everything stored for a connected source: every analysed conversation, every extracted fact, every snooze and dismissal, and the sync bookkeeping. This is immediate and irreversible; there is no waiting period and no support ticket required.

To delete your Fayla account itself — including your account record, subscription record, and every connected source's data — email hello@fayla.io from your account address and we will action it within 30 days. Deleting a connected source cascades to all conversation data belonging to it; deleting the account cascades to everything.

How long we keep things

• Conversation data is kept while the source is connected, and deleted when you delete it or disconnect that source.
• Account and subscription records are kept while your account exists.
• After account deletion we may retain the minimum billing and transaction records that tax and accounting law requires us to keep. These contain no email content.

9. Your rights under GDPR / UK GDPR

Your rights

If you are in the EU/EEA, the UK, or a jurisdiction with a similar law, you have the following rights over the personal data we hold about you:

• Access — a copy of the personal data we hold about you.
• Rectification — correction of inaccurate or incomplete data.
• Erasure — deletion of your data (see section 8 for how this actually works in Fayla).
• Restriction — limiting how we process your data in certain circumstances.
• Objection — objecting to processing based on our legitimate interest.
• Portability — receiving your data in a structured, machine-readable format.
• Withdrawing consent — where processing is based on consent, at any time, without affecting processing already carried out.
• Complaint — lodging a complaint with your local data protection supervisory authority.

To exercise any of these, email hello@fayla.io. We will not charge you for it and we will not make you justify the request. We aim to respond within 30 days.

If you are the person our customer emailed

You may be reading this because a business you corresponded with uses Fayla, which means we hold some data about you even though you never signed up for anything. That data is your email address, your name as it appeared in the message headers, and the facts our AI extracted from that conversation. We process it on the basis of legitimate interest (Art. 6(1)(f)) — which is exactly the basis that carries a right to object under Art. 21.

You can object, and we will act on it. Email hello@fayla.io from the address in question, or tell us which address you mean, and we will add you to our objection list. Concretely, that does two things:

• It erases what already exists, retroactively and everywhere. We sweep every conversation stored by every Fayla customer — not just the one who emailed you — and overwrite each matching record. Your email address, your name, and every extracted fact and score about the conversation are replaced outright. What survives is only the source's own internal thread identifiers, which carry nothing about you and exist so the customer's own sync does not break. This is not a soft delete and it is not reversible.
• It stops future processing. Every subsequent time any Fayla customer syncs a mailbox, threads involving your address are checked against the objection list before anything is fetched, analysed, or sent to an AI provider, and are set aside instead.

The objection is global by default: it is against Fayla processing your data at all, not against one customer's account, so it applies across every account and — as we add channels beyond email — across every channel where that address identifies you. The objection list itself is the one thing we must keep: it stores the address, a note that the reason was an objection, and the date, because that record is what keeps the suppression working. Ask us to remove it and we will, but doing so only stops future suppression — data already erased is gone and cannot be restored.

The same route covers a plain erasure request under Art. 17, since the mechanism is identical. If you would rather the business you corresponded with handled it, they can also delete their own stored copy of the thread themselves from inside Fayla.

Legal basis for processing

We do not send marketing email, so we do not rely on consent as a basis for any ongoing communication — the only emails we send are transactional (activation, account, and billing notices).

Automated decision-making

Fayla's AI scores and ranks conversations and drafts suggested replies. This is automated processing, but it does not make any decision about you or on your behalf with legal or similarly significant effect — it produces a ranked queue and a draft that a human (you) reviews, edits, and chooses whether to act on. Nothing is sent, and no account or service decision is made, without you.

International data transfers

Fayla's database and backend are hosted in the EU (see section 6), so your data is stored and processed there, not moved outside the EU/EEA in the ordinary course of running the product — except where it is sent to the AI provider for analysis (see section 7) under that provider's standard contractual terms, and the limited administrative access described below.

Fayla's controller (see section 1) is established in Moldova, which does not have an EU adequacy decision. Where operating the service requires the controller to access EU-hosted data from Moldova — for example, to answer a support request or investigate an abuse report — that access is treated as a restricted transfer under GDPR Chapter V and is safeguarded by the EU Standard Contractual Clauses (2021), which the controller adopts as data importer for this purpose. A copy is available on request.

10. Your rights under US state privacy laws

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or another US state with a comprehensive consumer privacy law, this section describes your rights and supplements the rest of this policy.

Categories of personal information

We collect these directly from you (account creation, settings) and from the Google APIs you authorise (see section 3), for the purposes described in section 4.

We do not sell or share your information

Fayla does not sell personal information, and does not "share" it as that term is defined under the CCPA/CPRA (disclosure for cross-context behavioural advertising). We have no advertising or analytics providers of any kind (see section 2). The providers listed in section 7 are service providers processing data on our behalf under contract, not independent third parties.

Your rights

• Right to know / access — what personal information we hold about you and how it is used.
• Right to delete — deletion of your personal information (see section 8).
• Right to correct — correction of inaccurate personal information.
• Right to opt out of sale/sharing — not applicable; we do not sell or share. If you visit our site with a Global Privacy Control signal enabled, we will honour it as an opt-out request regardless.
• Right to limit use of sensitive personal information — not applicable; we do not collect sensitive personal information.
• Right to non-discrimination — we will not charge you a different price or provide a different level of service for exercising any of these rights.

To exercise a right, email hello@fayla.io from your account address (this is how we verify it's you — Fayla is small enough that we don't need a separate identity-verification vendor). An authorised agent may submit a request on your behalf with written proof of authorisation. If we deny a request, you may reply to appeal; if you remain unsatisfied you may contact your state Attorney General or, in California, the California Privacy Protection Agency. We do not operate any financial incentive or loyalty program that involves your personal information.

11. Children

Fayla is a business tool and is not directed at children. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with data, contact us and we will delete it.

12. Changes to this policy

If we change what we collect, how we use it, or who we share it with, we will update this page and change the effective date at the top. For material changes — anything that expands what we do with data from a connected source, or adds a new one — we will notify you by email before the change takes effect.

13. Contact

Questions about this policy, a data request, or a security concern: hello@fayla.io. We read every message.