Version 2026-11, effective 2 December 2026 · Citron (operated by Inkblot Studio)
1. Who is responsible
1.1 Inkblot Studio OOD, a limited liability company registered in Bulgaria under UIC 208715250 (VAT number BG208715250), with its registered office at 19 Maragidik, floor 2, office 1, 8000 Burgas, Bulgaria ("Inkblot Studio", "we") is the controller for the personal data described in this policy: visitors to citronos.com, people who contact us, and the account and billing data of Citron customers. For anything about your personal data, write to support@citronos.com or to the registered office above.
1.2 Data that customers store in their Citron workspaces (for example their website enquiries, bookings and CRM records) is processed by us on the customer's behalf, as their processor. For that data the customer is the controller; our commitments are in the Data Processing Agreement (citronos.com/legal/dpa).
2. The website (citronos.com)
2.1 No tracking cookies. The website sets no cookies for analytics or advertising and loads no third-party trackers.
2.2 Anonymous page counts. To see whether the site works as a funnel, the site sends a small first-party event when a page is viewed, a request-access, sign-in or contact button is clicked, or an access request is sent. An event contains: the event name, the page path, the language, the referring website's domain, and a partner code if the page was opened through a partner link. It contains no IP address, no device identifier and nothing that identifies you. The site does not send these events when your browser signals Do Not Track or Global Privacy Control.
2.3 Stored in your browser. Your colour theme choice, and a partner code from a ?ref= link for 30 days, are kept in your browser's local storage so the site can remember them. They are not sent to us, except that the partner code is added to your access request when you send one.
2.4 Access requests. When you send the request-access form, we receive your name, work email, company, website (if you give one), what you need and your message, together with your IP address and browser type for spam protection. We use them to reply to you and to decide on your request (steps before a contract, at your request). They are stored in our own Citron inbox, hosted in the EU, and kept while we handle the request and any follow-up. We do not use them for marketing.
2.5 Sales assistant. If you use the chat on the website, your messages are sent to our server to generate a reply. When AI answers are switched on, the conversation is sent to Anthropic PBC to produce the answer. We do not keep the conversations after the reply is sent. Do not share sensitive personal data in the chat.
2.6 Server logs. Our hosting keeps technical logs (such as request time, path and IP address) for security and troubleshooting, for a limited period.
3. Customers and their users
3.1 Account data. When you create a CitronOS account we process your name, email address, sign-in and two-factor details, and the workspaces you belong to, to provide the service (performance of a contract).
3.2 Billing data. Payments are handled by Stripe. We receive the billing contact, the plan, invoices and payment status, but never full card numbers (performance of a contract, legal obligations for accounting).
3.3 Usage and security data. We record audit events (such as sign-ins and changes to settings) and product milestones (such as creating a workspace or publishing for the first time) to secure the service and to improve onboarding (legitimate interests).
3.4 Citron AI. When you use Citron AI, your messages, attachments, the page you are on and the workspace data needed for the answer are sent to Anthropic PBC to produce the reply. Citron AI can also remember useful facts about how you work, so it does not have to ask again. You can delete what it remembers or turn memory off in Settings → AI.
3.5 Dictation. If you dictate a message, the recording is sent to Eleven Labs Inc. in the USA to turn your speech into text. It is sent without your name or workspace. We do not keep the recording, and we ask Eleven Labs to delete each transcript as soon as we receive it. Eleven Labs handles the data under its own terms and may keep copies in backups for up to 30 days and in its own logs.
3.6 Files. Files you upload, including attachments to a Citron AI conversation, are stored on our servers in the EU. They are served from long, hard-to-guess web addresses that do not ask for a sign-in, so anyone who has an address can open the file.
4. Emails from us
4.1 We send service emails (sign-in, security, billing). We send product news only if you ask for it, and every such email has an unsubscribe link.
5. Sharing
5.1 We share personal data only with the sub-processors that help us run the service (hosting, payments, email, bot protection and, where switched on, AI), listed at citronos.com/security, and when the law requires it. We do not sell personal data.
6. International transfers
6.1 The service is hosted in the EU. Where a sub-processor processes personal data outside the EEA, the transfer relies on an adequacy decision or the Standard Contractual Clauses.
7. How long we keep data
7.1 Account data is kept while the account exists. Billing records are kept for as long as accounting law requires. Citron AI conversations are deleted after 30 days. What Citron AI remembers stays until you delete it. Attachments stay after their conversation is deleted, until you ask us to delete them (support@citronos.com). Workspace data, including all files, is deleted 90 days after the customer's agreement ends, unless the law requires otherwise. Anonymous website events do not identify anyone and are kept in aggregate.
8. Your rights
8.1 You can ask for access to, correction or deletion of your personal data, restrict or object to its processing, and ask for a copy in a portable format. Write to us at the contact above. For data in a customer's workspace, contact that customer first; we will help them answer.
8.2 You can complain to the Bulgarian Commission for Personal Data Protection (cpdp.bg) or to the supervisory authority where you live.
9. Changes
9.1 We will publish changes to this policy on this page and, for material changes, tell customers by email or in the console.