Privacy policy

01Where this service stands

Nauti7seven automated messaging is a pilot. It runs with human review: artificial intelligence writes drafts, but no reply is sent unless a person has read and approved it. It is not an autonomous system.

Fields marked PENDING are details that have not been settled yet. We would rather leave them visible than publish a legal statement that is wrong. This page will be updated as soon as they are confirmed.

02Who is responsible for your data

The data controller is Nauti7seven, the company you are writing to about boat charter and boat sales.

• Legal entity: LEGAL ENTITY PENDING CONFIRMATION
• Tax ID: TAX ID PENDING
• Registered address: ADDRESS PENDING
• Contact for privacy matters: CONTACT ADDRESS PENDING

03Who operates the system

ValleOS, a platform built and operated by Rafael David Pena from Colombia, provides the automation as a data processor on behalf of Nauti7seven.

ValleOS handles your data only on Nauti7seven instructions and only for the purposes described here. It does not use the data for its own purposes and does not pass it to anyone else.

04What data we handle

When you write to Nauti7seven on one of those channels, we handle:

• Your identifier on the platform: your phone number on WhatsApp, or your account identifier on Instagram and Messenger.
• The public or profile name the platform shows.
• The content of the messages you send, including any images and documents you attach.
• The voice notes you send and their transcription to text.
• The date and time of each message, and the channel it arrived on.
• Whatever you tell us so we can help you: for example dates you are interested in, how many people, or which boat you are asking about.

We do not need special category data (health, beliefs, biometrics and the like). Please do not send it through these channels.

This website, valleos.co, is a static site: it sets no cookies and uses no analytics or advertising. Typefaces are loaded from Google Fonts, so your browser makes a request to a Google server, which may record your IP address.

05What we use it for

• To receive, understand and answer your enquiries about boat charter and boat sales.
• To follow up on the conversation and pick it up again if you write back.
• To keep an internal record of what was discussed, so we can help you with context and have a record of it.

We do not use your data for advertising, we do not sell it, and we do not pass it to third parties for commercial purposes.

06How artificial intelligence is involved

We use AI models to classify conversations, summarise them and write draft replies.

No reply is sent automatically. The AI proposes a draft; a person at Nauti7seven reads it, corrects it if needed and decides whether to send it. That is a condition of the contract the system runs under, not a setting that can simply be switched off.

We do not make automated decisions that produce legal effects concerning you or similarly significantly affect you, within the meaning of Article 22 GDPR.

To produce those drafts, message content is sent to the AI provider listed in the table in the next section, which processes it on our behalf and on our instructions.

07On what legal basis

• Answering the enquiry you start: Article 6(1)(b) GDPR, steps taken at your request prior to entering into a contract. Where no contractual relationship follows, Article 6(1)(f), our legitimate interest in replying to someone who writes to us.
• Keeping a record of and following up the conversation: Article 6(1)(f), our legitimate interest in giving you an informed and traceable service.
• Compliance with legal obligations where they apply: Article 6(1)(c).

08Who else processes the data

These are the authorised providers. The list matches the subprocessor annex to the contract between Nauti7seven and ValleOS, and nothing is added to it without the controller prior written authorisation.

Meta Platforms is not a provider of ours. WhatsApp, Instagram and Messenger are the platforms you write to us on: Nauti7seven holds its own relationship with Meta as the owner of those accounts, and Meta processes your data under its own policies. Meta keeps its copy of the conversation even after we delete ours.

Where a provider processes data outside the European Economic Area, the transfer relies on TRANSFER MECHANISM PENDING CONFIRMATION.

09How long we keep it

We keep the conversation for as long as we are in contact with you and for RETENTION PERIOD PENDING after the last message. After that it is deleted or anonymised.

If you ask us to delete your data, we do it sooner: see the next section.

Where a law requires us to keep something, for tax or accounting reasons for instance, we will keep only what is strictly necessary and only for as long as that law requires.

10How to ask us to delete your data

You can ask us to delete your data at any time. You do not have to give a reason.

1. Send us DELETE MY DATA on the same channel you spoke to us on, from the same number or account. You can also write to CONTACT ADDRESS PENDING telling us the number or account you contacted us from.
2. We check that the request comes from that person. We may ask you to confirm it on the channel itself.
3. We delete the conversation history, your contact details and the transcriptions of your voice notes from our systems, within DELETION DEADLINE PENDING at the latest.
4. We confirm on the same channel once it is done.

Two limits worth knowing before you ask:

• We cannot delete the copy Meta keeps on WhatsApp, Instagram or Messenger, nor the one on your own phone. That is handled in those apps and with Meta.
• If a law requires us to keep a piece of data, we will block it and use it only to meet that obligation.

Once it is deleted, if you write to us again we start from scratch: we will not be able to recover the earlier history.

11Your rights

You can exercise the following rights at any time:

• Access: to know what data of yours we hold.
• Rectification: to correct anything inaccurate.
• Erasure: to have it deleted, as described above.
• Restriction: to have us keep it but stop using it.
• Portability: to receive the data you gave us in a machine-readable format.
• Objection: to object to our processing based on legitimate interest.
• Withdrawal of consent, where processing is based on it, without affecting what was done before.

To exercise them, write to CONTACT ADDRESS PENDING or use the same channel we spoke on. We will reply within one month.

If you believe we have not handled your request properly, you can lodge a complaint with the Spanish Data Protection Agency (AEPD), www.aepd.es.

12Security

Access to the system is limited to authorised people at Nauti7seven and ValleOS, using named accounts. Credentials are held in a secrets manager and actions on the data are logged. No system is infallible, and we will not claim otherwise.

13Changes to this policy

If anything changes, we will publish the updated version here with its date. This address is stable: it is the one registered as the privacy policy for the Nauti7seven messaging application.

14Contact

For anything to do with your data: CONTACT ADDRESS PENDING.