This Privacy Policy describes how Odoo Consulting Group, S.L. processes the personal data of users of the website www.axels.pro, of the Axels mobile app (iOS and Android) and of those who request information about or contract Axels services, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

1. Data controller

2. What data do we process?

2.1. Data collected by the mobile app

The Axels app is a work tool for users whose account has already been created by their organization; it has no public sign-up. It collects the following, always linked to your account:

DataHow it is collectedWhat it is used for
Name, email address and organizationFrom the account created by your organization, or from the identity provider when you sign in with Apple, Google or MicrosoftAuthenticating you and giving context to your conversations
Chat messages you writeYou type them in the appSo your digital team can reply and carry out what you ask
Voice notesRecorded with the microphone, only when you press the record buttonTranscribing them to text so they can be handled as any other message
Images and file attachmentsYou pick them from your gallery or cameraSo your digital team can read them and work on them
Device identifier for notificationsIssued by Apple (APNs) or Google (FCM) when the app is installedSending you business alerts and pending approvals. Never advertising
Usage events (screens viewed, sessions)Generated by the app as you use itInternal usage statistics and support. Not shared with third parties

The app does not read your phone contacts, does not access your location, includes no third-party advertising or analytics SDKs, and does not track you across other companies' apps or websites.

3. For what purpose?

4. Legal basis

5. Artificial intelligence and digital employees

Axels delivers its services through digital employees based on artificial intelligence. When you request a call or interact with one of them by voice or messaging, you are communicating with an automated system, not with a natural person, unless you are explicitly transferred to a human agent.

In accordance with article 22 of the GDPR and European artificial intelligence regulation, we inform you of this transparently. Decisions with significant effects always have human oversight; we do not make decisions based solely on automated processing that produce legal effects concerning you without your knowledge.

5.1. AI providers that receive your content

The language and voice models that power the digital employees are provided by third parties. This means that, in order to deliver the service, the content of your conversations leaves our servers and is sent to the following providers:

ProviderWhat it receivesLocation
Anthropic, PBC (Claude models)Your messages, any attachments you send, your name and organization as context, and the business data needed to handle your requestUSA
OpenAI, L.L.C.The same, when your organization has this provider configured as its alternative modelUSA
ElevenLabs Inc.The audio of your voice notes (to transcribe it) and the text of replies (to read them aloud)USA

We have signed art. 28 GDPR data processing agreements and Standard Contractual Clauses for international transfers with all of them, so they provide a level of protection equivalent to that required within the European Economic Area. None of them uses your content to train their models, in accordance with the terms of their enterprise APIs, and none of them shares it with third parties or uses it for advertising purposes.

In the mobile app, this information is shown to you inside the app and your explicit consent is requested before anything is sent to these providers. You can review it and withdraw that consent at any time under Settings › Data and AI; if you withdraw it, the digital employees stop processing what you write.

6. Retention period

We keep your data for as long as necessary to handle your request and, where applicable, for the duration of the commercial relationship. Once it ends, the data will be kept blocked for the periods legally required to address any potential liabilities. Data processed on the basis of your consent will be kept until you withdraw it.

7. Who do we share your data with?

We do not transfer your data to third parties, except where legally required. To deliver the service we rely on providers acting as data processors, with whom we have signed the contracts required by art. 28 GDPR:

ProviderPurposeLocation
Odoo S.A. (Odoo.sh)CRM and platform hostingEuropean Union
DigitalOceanInfrastructure and storageEuropean Union (Amsterdam)
Retell AITelephony and voice for digital employeesUSA
Anthropic, PBCLanguage models for the digital employees (see section 5.1)USA
OpenAI, L.L.C.Alternative language model (see section 5.1)USA
ElevenLabs Inc.Speech transcription and synthesis (see section 5.1)USA
Apple Inc. / Google LLCDelivery of push notifications to the mobile app (APNs and FCM)USA
Google (Workspace)Email and productivityUSA
Meta PlatformsMessaging (WhatsApp Business)USA / Ireland

Some providers are located outside the European Economic Area. In those cases, international transfers are carried out with the appropriate safeguards provided for in the GDPR (European Commission Standard Contractual Clauses or adequacy frameworks in force).

8. Your rights

You may exercise the following rights by sending a request to privacidad@axels.pro, stating the right you wish to exercise and enclosing a copy of an identity document:

If you believe we have not properly addressed your rights, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

9. Security

We apply appropriate technical and organizational measures to protect your data against unauthorized access, loss, or alteration, including encryption of credentials and sensitive data and audit logging of access.

10. Changes to this policy

We may update this Privacy Policy to adapt it to regulatory or service changes. We will publish any amendment on this same page, stating the date of the last update.