Privacy Policy

1. Data Controller

The data controller is SYSTANA LLC, Identification Code: 405378342, located at Krtsanisi Str. 22/24 D 45, Tbilisi, Georgia.

Contact: shellpilot@sistana.ge

2. What Data We Collect

We follow the principle of data minimization. We collect only what is strictly necessary to provide and operate ShellPilot.

3. What We Do NOT Collect or Store

• Chat conversations or message content
• Generated scripts or code
• Script execution output or results
• Credentials, passwords, or secure strings
• Files, documents, or data from your local system
• System configuration, network topology, or environment details
• Screenshots or images sent to the AI
• IP addresses (beyond what is technically necessary for the connection)

4. AI Data Processing

ShellPilot is designed with a strict separation between AI communication and local execution. By default, only the text you type in the chat is sent to the AI processing service. This typically consists of task descriptions, questions, and error messages — none of which need to contain personal data.

The AI does not automatically access, read, or transmit any local data. Additional data (script output, screenshots, files) is only sent if you explicitly choose to do so via a deliberate action.

Credentials, passwords, and secure strings are never intentionally sent to the AI by ShellPilot and must not be typed into normal chat. Runspace variables, session state, environment variables, system configuration, and network topology are never automatically collected or sent by ShellPilot.

ShellPilot is designed to support GDPR-conscious use through data minimisation, no server-side chat storage, EU-hosted proxy infrastructure, and user-controlled transmission of optional context. Normal usage of the AI does not require the transmission of personal data.

Chat messages are processed in real-time and are not stored on our servers. No conversation history is retained.

4.1 Cloud AI Mode

Chat text is routed through our proxy to an external AI processing service. The proxy performs authentication and rate limiting only — it does not log, store, or inspect message content.

4.2 Local AI Mode

Local LLM inference runs on customer-controlled infrastructure. Prompts, scripts, and output for that inference do not leave your network. The application still contacts the ShellPilot Azure proxy at launch to verify subscription and activation. While a Local LLM session is already running, the licence token is refreshed hourly when online; if that refresh is temporarily unavailable, Local AI requests can continue for up to twenty-four (24) hours since the last successful refresh, after which AI requests are blocked until proxy connectivity returns.

5. Your Responsibility for Data Sent to AI

You control what data is sent to the AI. ShellPilot is designed to work without personal data — its purpose is script generation and error troubleshooting.

If you choose to send additional data (script output, screenshots, file contents), you do so via explicit action. If any of that data contains personal or regulated information, you are responsible for ensuring compliance with applicable data protection regulations.

We do not use any tracking or analytics services. No usage profiles are created.

6. Payment Processing

Payment processing for monthly online subscriptions is handled by FastSpring, the Merchant of Record for that purchase path. FastSpring collects and processes payment information (credit card details, billing address, etc.) in accordance with their privacy policy. We never receive or store your payment card details. Direct B2B annual invoice sales by SYSTANA LLC are handled separately by bank transfer and are not processed by FastSpring.

See: FastSpring Privacy Policy

7. Legal Basis for Processing (GDPR)

We process personal data on the following legal bases:

• Contract performance (Art. 6(1)(b) GDPR): Email address and subscription data are necessary to provide the product and manage your license.
• Legitimate interest (Art. 6(1)(f) GDPR): Device identifiers are necessary for license enforcement and abuse prevention.
• Consent (Art. 6(1)(a) GDPR): Marketing communications, if applicable, are sent only with your explicit consent.

8. Your Rights (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or any jurisdiction with similar data protection laws, you have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your personal data ("right to be forgotten").
• Restriction: Request restriction of processing in certain circumstances.
• Portability: Request your data in a machine-readable format.
• Objection: Object to processing based on legitimate interest.
• Withdraw consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at shellpilot@sistana.ge. We will respond within 30 days.

9. Categories of Service Providers

To provide ShellPilot, we engage the following categories of service providers:

• AI processing services: Process chat messages for script generation (Cloud AI Mode only)
• Card payment processing (monthly online subscriptions): FastSpring (USA / Ireland EU subsidiary) handles card-based payment transactions for the monthly online subscription path as Merchant of Record — including billing, tax calculation, and refund processing. The direct B2B annual invoice path is not handled by FastSpring.
• Cloud infrastructure: Microsoft Azure (EU region) hosts our proxy, authentication services, and subscription/license data
• AI inference: Google Ireland Limited (Vertex AI, EU region europe-west4) processes Cloud AI chat requests
• Email delivery services: Deliver activation codes and account-related notifications
• Cloud hosting: Infrastructure for our proxy and licensing services

A detailed list of specific service providers is available upon request by contacting shellpilot@sistana.ge.

10. Data Transfers

The core ShellPilot infrastructure is operated in the European Union:

• ShellPilot proxy and licensing services are hosted on Microsoft Azure in an EU region.
• Cloud AI inference for chat requests is processed by Google Vertex AI in europe-west4.
• Payment processing is handled separately by FastSpring under its own terms and privacy policy.

Where individual sub-processors of the above services may transmit, replicate, or back up data outside the EEA in the course of their own operations, appropriate safeguards such as Standard Contractual Clauses (SCCs) apply in accordance with their respective terms. We do not direct any element of the ShellPilot chat or script pipeline to a non-EU region by design.

In Local AI Mode, inference itself stays on your infrastructure; only the licence verification path described in Section 4.2 contacts the EU-hosted proxy.

11. Website Services, Cookies, and Embedded Third Parties

The website at shellpilot.app uses only technically necessary cookies for its own operation. No third-party advertising cookies, behavioural tracking, or user-profiling analytics are loaded by the website itself.

The pages on shellpilot.app do load a small number of third-party services that are necessary for the website to function. Their use is disclosed here:

• Google Fonts (Google Ireland Limited / Google LLC): the website loads the Inter and JetBrains Mono web fonts from fonts.googleapis.com and fonts.gstatic.com. When your browser requests these fonts, technical request data including your IP address is transmitted to Google for the duration of the request. Legal basis: legitimate interest in a consistent, accessible visual presentation (Art. 6(1)(f) GDPR).
• Cloudflare Turnstile (Cloudflare, Inc.): used on the demo request form and on the checkout page for bot and abuse prevention. Turnstile collects technical signals from the browser session needed to assess automation; it is not a behavioural tracker. Legal basis: legitimate interest in protecting the forms and the checkout against automated abuse (Art. 6(1)(f) GDPR).
• Frankfurter / ECB-derived FX API: on the checkout page, an exchange rate (USD→EUR) is fetched from api.frankfurter.dev to display an indicative EUR amount for the direct B2B invoice path. The request does not intentionally include personal data; technical request metadata such as your IP address reaches that API for the duration of the call.
• FastSpring (FastSpring, Inc., USA / EU subsidiary): online card checkout for monthly online subscriptions is handled by FastSpring as Merchant of Record for that path. When you proceed with an online purchase, your interaction continues under FastSpring's own privacy policy. FastSpring is not involved in the direct B2B annual invoice path.
• Email delivery (transactional): trial codes, activation codes, and account-related notifications are sent through a transactional email service provider on our behalf. Only the data required to deliver the message (email address and message body) is processed for that purpose.

Demo request form (demo.html): the form collects your name, company, work email, and an optional message. This information is used only to evaluate and respond to your demo or trial request and to follow up on it. It is retained for as long as needed to handle that request and any subsequent commercial relationship; after that, it is deleted in accordance with applicable retention requirements. The form is submitted over an encrypted connection and is protected by Cloudflare Turnstile (see above).

12. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encrypted communication (TLS) for all data in transit
• Mutual authentication between client and proxy
• No persistent storage of chat content or scripts
• Server-side enforcement of rate limits and access controls
• Hashed device identifiers (no plain-text hardware information stored)

13. Children

ShellPilot is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us for immediate deletion.

14. Data Deletion

Upon cancellation of your subscription, we delete your account data (email address, device identifiers, subscription status) within 30 days. No chat data needs to be deleted because it is never stored in the first place.

To request deletion of your data at any time, contact shellpilot@sistana.ge.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or through the product. The "Last updated" date at the top of this page indicates the most recent revision.

16. Direct B2B Invoice Sales — Additional Data Processing

For business customers who purchase the annual invoice path operated directly by SYSTANA LLC (see Terms of Service Section 18), the following additional data is processed independently of the online subscription path:

Legal basis: Art. 6(1)(b) GDPR (performance of contract) and Art. 6(1)(c) GDPR (legal obligation under tax law).

This data is processed exclusively by SYSTANA LLC for the purpose of invoice issuance, bank-transfer payment processing, and tax-compliance reporting under the laws of Georgia. No data from this path is shared with our online reseller or any AI processing service.

Inquiries about data processed under the invoice path: shellpilot@sistana.ge

17. Contact

For privacy-related inquiries:

SYSTANA LLC
Krtsanisi Str. 22/24 D 45
Tbilisi, Georgia
Email: shellpilot@sistana.ge

For payment-related privacy inquiries, contact FastSpring directly at FastSpring Support.