LEGAL
Privacy Policy — Hermina Cloud
This policy describes how Hermina Cloud processes personal data. It is a product draft for legal review, not a lawyer-stamped opinion or a filed notice with a data-protection authority.
Who is responsible for Cloud account data
For Hermina Cloud (the hosted service at cloud.artificialmanufactory.com), the controller of Cloud account data is Artificial Manufactory, Osasco, SP, Brazil — the name and place already used in product email. The public site is hermina.artificialmanufactory.com. Sign-in codes are sent from login@artificialmanufactory.com.
We do not publish a CNPJ or a named Data Protection Officer. For privacy requests use derekoob@hotmail.com or Telegram @x_panika.
Three people in the data
Cloud account holder: the person who signs in, pays, and connects WhatsApp or Telegram. That person is our customer for the hosted service.
People in their chats: contacts, group members, and anyone whose messages, names, or phone numbers appear because the customer connected a messenger. Hermina processes that content so the agent and inbox can run. Those people are not Cloud customers, and we do not treat their messages as a training dataset.
Visitors of the marketing site: people who open hermina.artificialmanufactory.com (and related landing pages) without a Cloud account.
What we process
Account and login: Telegram user id and name when you sign in with Telegram OAuth (OIDC). That login can include phone_number when Telegram provides it. Email address and one-time magic-link codes when you sign in by email via Resend from login@artificialmanufactory.com; codes expire in 15 minutes. Phone number also when you connect Telegram or WhatsApp as a messenger.
Payments: plan choice; PIX receipts (photo or PDF) you send in the HerminaAI Telegram bot — those files often show CPF, CNPJ, or bank details; Stripe customer and subscription identifiers. Card numbers stay with Stripe. We do not store full card data on Hermina servers.
Messenger sessions: WhatsApp session material (Baileys) stored on the tenant volume; Telegram MTProto api_id / api_hash (stored encrypted) and related session material so the agent can stay connected.
Inbox and agent: mirrored chat history (including groups, including when the agent is off). Hermina Cloud does not keep profile photos of the account holder’s WhatsApp or Telegram contacts in the mirrored inbox; the inbox UI uses initials only. Your own Cloud profile photo, if you upload one, is stored on the host under the Cloud data directory (profile-avatars). We store media type (not a full media archive as a training set); agent memory and files; prompts you send; model outputs; operational logs. You can delete one mirrored chat from the Cloud inbox; that is not deletion of the whole account.
Voice: audio you submit for transcription, processed to produce text for the agent.
Cloud computer: browser or computer-use / VNC activity that runs inside the tenant when you use that feature.
Site and panel: the Cloud layout loads Telegram’s Mini App script (telegram-web-app.js) before the page becomes interactive when you open Cloud inside Telegram. Cookies or localStorage hold theme, language, session token, and similar strictly functional UI state. We do not run a marketing cookie wall.
Purposes and legal bases
Contract (providing the Cloud service you asked for): creating and authenticating the account, taking payment, connecting messengers, running Hermes (the hosted WhatsApp/Telegram agent), review-before-send, inbox mirroring, memory, models, voice transcription, and cloud computer when those features are part of your plan.
Legitimate interest: keeping the service secure, preventing abuse, debugging failures, and understanding how the product is used at an operational level — not to build a public training corpus from third-party chats.
Legal obligation: tax, accounting, or authority requests where Brazilian or other applicable law requires us to keep or disclose information.
We do not rely on consent as the basis for processing third-party chat content.
Third-party messages
Operational history on your instance includes counterparties’ messages so the agent can reply (including assist/auto modes) and so the Cloud inbox can show chats. That history is personal data of those people. It is not used as a training or product-improvement dataset under these terms; prompts you send to Hermina may still be used to improve the system, response quality, and security.
Outbound agent replies are identified with the “[agente]” / “[Agent]” prefix. Stealth mode (unlabeled replies) was removed and is not offered.
The Cloud customer is responsible for having a lawful reason to connect the messenger account, and for any disclosures the law requires toward their own contacts. Hermina processes that content to run the service you requested — not because the other person signed up with us.
Subprocessors and international transfers
To run Cloud we use: Stripe (payments); Telegram (login, bot, and user API); Resend (email codes from login@artificialmanufactory.com); large-language-model providers — default DeepSeek V4 Flash via OpenCode Go, and optionally OpenAI, Anthropic, or OpenRouter depending on configuration; and the VPS / hosting provider that runs tenant instances.
WhatsApp connectivity uses a Baileys session on the tenant volume; it is not a separate WhatsApp Business Cloud API product in this stack.
Prompt text, chat context, and related content sent to an LLM leave our tenant and may be processed outside Brazil and outside the EEA. Stripe, Telegram, Resend, and hosting may also store or process data outside Brazil. If you are in the EEA/UK, that is an international transfer. We do not publish a fake vendor list: only processors the product actually uses are named here.
Retention
We keep Cloud data while the account and tenant instance exist so the service can function. We do not publish a fixed deletion calendar.
If backups exist as part of ordinary hosting, they last until those copies rotate. We do not invent a retention number we cannot verify.
You can delete your Hermina Cloud account yourself in the Cloud web Settings, in the Android app Settings, or at https://cloud.artificialmanufactory.com/account/delete. Deletion is irreversible: the account, tenant instance, bots, inbox mirrors, files, and messenger session credentials are removed. Deleting one inbox chat is not account deletion. We may keep what the law requires (for example a payment record).
Your rights (LGPD and GDPR)
Depending on the law that applies to you, you may request access, correction, deletion, portability, information about processing, and opposition to processing, and you may withdraw consent where consent was actually used.
You may complain to the ANPD in Brazil (Autoridade Nacional de Proteção de Dados) and, if GDPR applies, to a supervisory authority in the EEA/UK.
How to exercise rights: delete the Hermina Cloud account in Settings or at https://cloud.artificialmanufactory.com/account/delete, or email derekoob@hotmail.com or Telegram @x_panika stating that you want a privacy request for Hermina Cloud. Export of Cloud consumer account data is on request through those channels — there is no self-serve export API in this product.
Cookies and local storage
The marketing site and Cloud panel store language and theme (for example hermina_lang, hermina-theme, hermina_cloud_theme) and a session token so you stay signed in. Sidebar widths and similar UI flags may also sit in localStorage. Inside Telegram, Cloud also loads telegram-web-app.js so the Mini App can sign you in.
These are strictly functional. We do not show a cookie banner in this version because we are not asking for ePrivacy-style marketing-cookie consent. If we add non-essential tracking later, we will update this policy and the product.
Security
Traffic to the Cloud panel uses TLS. Tenants are isolated from each other at the hosting layer we operate. Telegram MTProto api_id and api_hash are stored encrypted (Fernet). This is a high-level description, not an invitation to probe the infrastructure.
Incidents
If a security incident involving personal data must be notified under LGPD or GDPR, we will notify the people and authorities the law requires. We do not publish a fake response SLA in this draft.
Self-host versus Cloud
Hermina Cloud is the hosted product. We operate the servers and process data as described here so we can provide that product.
Self-host is a separate distribution: you (or your organization) run the software on your own machine or server. In that case you are the controller of that instance. This Cloud policy does not make us the controller of a self-hosted deployment we do not operate.
Children
Hermina Cloud is not directed at people under 18. Do not create an account for a child, and do not use the service to process children’s data.
Updates
We may change this policy when the product or the law changes. The date at the top is the current version: 28 August 2026. Continued use of Cloud after an update means the new text applies to later processing. Material changes will be reflected on /privacy and, where we can, in the bot.