Privacy Policy

DRAFT · FOR REVIEW

DRAFT · v0.1 · 13 AUG 2026

What Glasshouse does with your data, who processes it and how long it stays, all written from what the product actually does. Two things hold whatever this page ends up saying: your materials never train models, and every persona is synthetic.

A draft for Creative Human and its counsel to correct and sign off. Everything in square brackets with underscores is a placeholder for a particular the engine has no way to verify: an invented register number, an invented address or an invented assurance would each be worse than a visible gap. 10 particulars still to fill on this page.

Controller

PENDING

The controller under Art. 4(7) GDPR is [COMPANY: full legal name including legal form, _____], [ADDRESS: street, postcode, city, _____], support@creativehuman.ai.

PENDING

[DATA PROTECTION OFFICER: name and contact if one has been appointed; otherwise this line is dropped, _____]

Account and sign-in

Signing in runs through Google Identity (Google SSO). From it we receive your name, your email address and your Google account identifier. We set a signed session cookie that lasts seven days; this route stores no password.

The legal basis is Art. 6(1)(b) GDPR: without an account there is no access to the product.

Materials, questions and runs

What you upload and type, meaning documents, images and the decision question, is stored so a run stays reproducible and its report stays evidenced. From those materials the engine builds the graph, the cast, the personas' posts and the report.

The legal basis is Art. 6(1)(b) GDPR. Retention follows the v1 policy: kept until deleted, deletable on request, stored in the EU.

PENDING

We train no models on your materials. Whether the providers we use may keep or use inputs for their own purposes is a matter of the contract with them: [PROVIDER CONTRACTS: confirm the no-training-on-inputs assurance from each provider and name it here, _____]

PENDING

If your materials contain personal data about other people, you stay the controller for it and we process it on your instructions. [PROCESSING AGREEMENT WITH CUSTOMERS: settle the Art. 28 GDPR template and how it gets signed, _____]

Operation, security and billing

We log technical events with trace identifiers, and what a run consumed in tokens and credits. The legal basis is Art. 6(1)(f) GDPR, a legitimate interest in a service that runs, stays secure and bills correctly. For the billing records themselves it is Art. 6(1)(b) and Art. 6(1)(c) GDPR.

Recipients and processors

Google (hosting, sign-in, embeddings): the service runs on Google Cloud, with the database on CloudSQL and the stored files in Cloud Storage. Google Identity carries the sign-in. Vertex AI computes embeddings, the numeric vectors the report measures similarity with, and computing them means the text itself goes there: passages from your documents, the personas' posts, and the text of your question and of the report. What comes back is numbers; what is sent is content.

Alibaba Cloud Model Studio (inference): every model call the product makes goes there, carrying the text of your materials, your question, the personas' posts and the report.

PENDING

[PROCESSING AGREEMENTS: check the Art. 28 GDPR contracts with both providers and record what is in force here, _____]

Transfers to third countries

PENDING

[RESIDENCY, RE-AUDIT OPEN: this paragraph states an interim posture and is re-checked before the first external customer account is opened, _____] Inference reaches an endpoint in the eu-central-1 region. What decides where execution happens is not the region but the service deployment scope of the workspace in use, and under the current interim posture that scope is global. Processing outside the EEA is therefore not excluded, and this page deliberately makes no claim of EU-only inference.

PENDING

[TRANSFER BASIS: record the standard contractual clauses in force with each provider and check the transfer impact assessment, _____]

How long data stays

PENDING

Materials and runs stay until you delete them or ask us to, which is the v1 policy and exists so a report can still be evidenced months later. Account data stays while the account does. [LOGS AND BILLING RECORDS: set the retention periods, taking the commercial and tax-law periods into account, _____]

Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection to processing based on legitimate interests (Art. 21). Any consent you have given can be withdrawn at any time with effect for the future (Art. 7(3)). Write to support@creativehuman.ai.

PENDING

Separately from that, you can lodge a complaint with a supervisory authority (Art. 77 GDPR). [SUPERVISORY AUTHORITY: the authority for the company's registered seat, with its address, _____]

No decision about you is taken automatically. Glasshouse rehearses a decision and writes a report about it; what is then done with that report is decided by people. There is no automated decision-making producing legal effects for you within the meaning of Art. 22 GDPR, and no profiling of you on which such a decision could rest.

Cookies and session

The cookies this product sets are the ones it needs to work: the signed session cookie of the sign-in, a short-lived state cookie that protects the sign-in itself, and one cookie each for the language, the colour scheme and your answer to the cookie notice. The legal basis is §25 Abs. 2 Nr. 2 TDDDG. No third-party trackers are loaded.

This build sets no analytics cookie and loads no measurement tool, and the cookie notice therefore asks for no analytics permission: there is nothing to permit. If analytics is ever introduced, it is asked for first and runs only on an answer given then.

Personas are synthetic

The personas in a run are invented. They are built from roles and traits, never from profiles of real individuals, and Glasshouse keeps no register of real people for a run to be matched against. Real organisations can appear in your materials and in a report; a real, identifiable individual as a persona is ruled out.

This is an English rendering. The binding version is the German one, served when the language is set to German.

Back to the site