Privacy Policy

1. Who We Are, and How to Reach Us

Virgo Command is operated by Prem Devkota, a sole trader based in the United Kingdom, trading as PD Link HQ. For data protection purposes we are the data controller for the personal data described in this notice.

Contact: privacy@virgocommand.com. A postal address is available on request.

If you are unhappy with how we handle your data you can complain to the UK regulator, the Information Commissioner's Office, at ico.org.uk/make-a-complaint or on 0303 123 1113. We would rather you told us first so we can put it right, but you do not have to.

2. Why We Are Allowed to Use Your Data

UK GDPR requires us to have a lawful basis for everything we do with your data. Ours are:

• Contract. Running your account, storing what you put into it, and letting Lily and your officers answer you. Without this the product does not work.
• Legitimate interests. Keeping the service secure, preventing abuse, and fixing faults. We have weighed this against your interests and you can object at any time.
• Consent. Anything optional: connecting an outside account, using the microphone, and health data. You give it deliberately and you can withdraw it at any time without losing access to the rest of the product.
• Legal obligation. Keeping records we are required by law to keep, such as billing records.

3. Voice, and the Microphone

Speaking to Lily is optional. Nothing is recorded until you tap to start listening, and the microphone stops when the turn ends or you close the booth.

• What you say is transcribed by the speech recogniser built into your phone. On iPhone that is Apple's; on Android it is Google's. That transcription may happen on the device or on their servers, depending on your phone's settings, and it is governed by their privacy terms as well as ours.
• The text of your words is then sent to us, and on to the AI providers in section 8, exactly as if you had typed it.
• Lily's reply is sent as text to ElevenLabs, which returns the audio. We do not send them your voice.
• We do not keep the audio. We store the transcript as part of your conversation, and you can delete it.

If you never grant the microphone permission, or withdraw it in your phone's settings, everything else continues to work and you type to Lily instead.

4. Health Data, and Your Explicit Consent

Health information is what the law calls special category data, and it gets stricter treatment than anything else here.

• We only receive health data if you deliberately set it up, by creating an iOS Shortcut of your own and giving it your personal webhook token. It is off until you do that, and we ask you to confirm it explicitly first.
• Our lawful basis is your explicit consent under Article 9(2)(a) UK GDPR. Nothing else.
• You can withdraw it at any time from Settings. Withdrawing stops any further data arriving and deletes what we already hold.
• We do not use health data for advertising, we do not sell it, and we do not use it to make any automated decision about you.

5. Data About Other People

If you connect a calendar or contacts, we necessarily receive information about people who are not our users: their names, email addresses, and when you are meeting them. We process it only to show you your own diary and contacts, we do not build profiles of those people, and we do not contact them. If one of them asks what we hold, write to privacy@virgocommand.com and we will deal with it.

6. What We Collect

We only collect what is necessary to operate your account and deliver the service:

• Name, email address, and country (at signup)
• Data you create inside Virgo. Notes, tasks, calendar entries, preferences
• Usage patterns to improve Lily AI responses (anonymised)
• Payment information is processed by Stripe. We never store card details

7. How We Use Your Data

• To operate your Virgo Command account and deliver personalised features
• To power Lily AI. Your data trains your personal assistant, not a public model
• To send essential account notifications (password resets, billing)
• To improve the product based on anonymised, aggregated usage data

We do not sell your data. We do not share it with advertisers. Ever.

8. Where Your Data Lives

Your data is stored on servers in London, United Kingdom, wherever in the world you are. We do not operate data centres in other regions, and we will say so plainly here if that ever changes.

Some processing happens outside the United Kingdom. When you talk to Lily, your message is sent to the AI providers listed in section 6 for the sole purpose of generating a reply. Those providers operate internationally, and each is bound by a data processing agreement.

All data is encrypted at rest (AES-128, Fernet) and in transit (TLS 1.3). Encryption keys are held by us on the server, so we can operate the service on your behalf. This is standard practice and it means we could technically access stored data. We do not do so except where necessary to run or protect the service.

9. Country-Aware Compliance

Virgo Command automatically detects your country and applies the correct legal framework:

• GDPR. European Union and United Kingdom
• CCPA/CPRA. California, United States
• LGPD. Brazil
• DPDP. India
• PDPA. Singapore
• POPIA. South Africa

No fine print games. Your rights are applied automatically.

10. Your Rights

Regardless of where you are, you always have the right to:

• Export all your data with one click
• Delete your account and all associated data permanently
• Request a copy of everything we hold about you
• Correct inaccurate personal information
• Withdraw consent at any time, without losing access to the rest of the product
• Be forgotten. Full data erasure on request
• Ask us to restrict processing while a dispute is resolved
• Object to processing we carry out under legitimate interests
• Complain to the Information Commissioner's Office. See section 1

11. Third-Party Services

• Stripe. Payment processing (PCI-DSS compliant)
• AWS. Infrastructure and storage (ISO 27001 certified)
• Google OAuth. Optional sign-in (we only receive name and email)
• Resend. Transactional email delivery
• AI model providers: Anthropic (Claude), Google (Gemini) and OpenAI. What you send to Lily and your officers (your messages, and the notes, tasks or documents you ask them to work with) is processed by these providers under contract, solely to generate your reply. Under their enterprise API terms, your content is not used to train their models. Each retains content only briefly for abuse monitoring, in line with their published policies, and we hold a data processing agreement with each.
• ElevenLabs. When Lily speaks, the text of her reply is sent to ElevenLabs to generate the audio.
• Open banking provider. If you connect a bank account, a regulated open banking provider handles that connection. We never see your banking credentials.
• Cookieless analytics provider. Aggregate page statistics with no cookies and no personal data.

We use no advertising pixels, no social media SDKs and no cross-site tracking. For product analytics we use a cookieless service that stores no personal data.

12. Cookies

We use only essential cookies required for authentication and session management. No tracking cookies. No third-party cookies. See our Cookie Policy for details.

13. Data Retention

Your data is retained for as long as your account is active. When you delete your account, all personal data is erased immediately and permanently, not on a delay. Encrypted backups are overwritten on a rolling 30 day cycle. Anonymised usage data may be retained for product improvement.

14. Contact

For privacy questions, data requests, or concerns:

Email: privacy@virgocommand.com

We respond to all privacy requests within 72 hours.