Privacy Policy

Last updated: July 16, 2026

This Policy explains how Replacing Humans, S.L. ("AutoSetter", "we", "us" or "our") processes personal data through the AutoSetter website, application, integrations, support and related services.

Controller contact: Replacing Humans, S.L., Spanish tax ID B27595743, Calle Paca Diaz 12, Bajo B, 28023 Madrid, Spain, nico@autosetter.live.

1. Our roles

We act as controller for data whose purposes and means we determine, such as account administration, commercial contacts, billing, security, support and website operation.

When a customer instructs AutoSetter to process Instagram messages, leads and end-user data solely to provide the Service, the customer is normally the controller and Replacing Humans, S.L. is the processor. The applicable signed data-processing terms govern that activity. End users should normally contact the business whose Instagram account they interacted with.

2. Data we process

Depending on use, we may process account and organization details; authentication and session information; Meta and Instagram identifiers, tokens, webhooks, comments and messages; conversations, leads, CRM and booking context; business configuration; model inputs and outputs; files and media; usage, security, diagnostic and support information; and billing or contractual records.

3. Purposes and legal bases

We process data as necessary to provide and support the Service, connect integrations, operate automation, secure the platform, prevent misuse, troubleshoot, manage billing and contracts, comply with legal obligations and improve reliability.

Where GDPR applies, the legal basis depends on the activity and may be performance of a contract, compliance with a legal obligation, our or a third party's legitimate interests after balancing the relevant rights, or consent where required. Customers are responsible for selecting and documenting the lawful basis for data they instruct us to process about their leads and end users.

4. AI processing and improvement

AutoSetter may send relevant conversation content, business configuration, prompts, transcripts, attachments and operational context to authorized AI and infrastructure providers to generate replies, classify leads, summarize conversations, transcribe media and operate product features.

When automation is enabled, messages may be generated and sent without prior human approval. Customers can pause automation and intervene using the controls available in the product.

We may use data for security, evaluation and improvement where we act as controller and have an appropriate legal basis. Customer end-user data that we process as processor is not used for an independent training purpose unless that use is covered by separate documented instructions or authorization, an appropriate legal basis and the required notice. We do not authorize a third-party AI provider to train its general models on customer data unless that use has been specifically disclosed and lawfully authorized.

5. AI transparency

Where applicable law requires disclosure that a person is communicating with an AI system, customers must use the disclosure functionality or wording provided for that purpose and must not remove or conceal a legally required notice.

6. Recipients and international processing

We share data only as needed with service providers that support authentication, Meta and Instagram connectivity, hosting, storage, AI processing, monitoring, email, payments and optional integrations, or with advisers and authorities where lawfully required. Optional providers receive data only when the corresponding feature is used.

Some providers may process data outside the European Economic Area. Where GDPR requires it, restricted transfers are covered by an applicable adequacy decision, Standard Contractual Clauses or another valid transfer mechanism. We do not sell personal data.

7. Security

We use technical and organizational measures appropriate to the risk, including access controls, protected communications, separation between customer environments, monitoring and protection of integration credentials. No service can guarantee absolute security.

8. Retention

We retain personal data only for as long as needed for the active Service, the purpose for which it was collected, documented customer instructions, security and dispute handling, or applicable legal obligations. The period depends on the type of data and our role as controller or processor.

When a contract ends or a valid deletion instruction is received, customer data is handled in accordance with the applicable signed agreement, legal obligations and backup lifecycle. Billing, tax and contractual records may be retained for the periods required by law. Information that has been irreversibly anonymized may be retained longer.

9. Cookies and analytics

AutoSetter uses cookies or browser storage for authentication, security, preferences and consent choices. Vercel Web Analytics may be used for aggregated audience measurement in accordance with the consent configuration described in our Cookie Policy.

We do not currently use Meta Pixel, Google Analytics or PostHog in the application.

10. Rights

Where applicable, you may request access, rectification, erasure, restriction, portability or objection, withdraw consent, and request information about automated processing. Email nico@autosetter.live. We may verify your identity and authority and will respond within the period required by applicable law.

You may complain to the Spanish Data Protection Agency (AEPD) at aepd.es or to the competent authority in your country.

If we process your information only for one of our customers, we will refer the request to that customer or assist it as processor.

11. Children

AutoSetter customer accounts are not intended for people under 18. Customers must not knowingly use AutoSetter to target or collect children's data without the authorization, notices and safeguards required by law.

12. Changes and contact

We may update this Policy to reflect legal, provider or product changes and will give notice of material changes where required.

Replacing Humans, S.L. Calle Paca Diaz 12, Bajo B 28023 Madrid, Spain Spanish tax ID: B27595743 Email: nico@autosetter.live