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SelimReviewer privacy policy

Version: v1.0, 2026-11-05

1. Who we are

Modern Miracle OÜ, registry code 17494745, Tornimäe tn 5, 10145 Tallinn, Harju County, Estonia ("MM", "we"), operates SelimReviewer, a service that drafts, checks and publishes replies to reviews on Google Business Profile for businesses. Privacy contact: hello@modern-miracle.com. Our data protection officer is Sarra-Maryam Fezzani, smf@modern-miracle.com.

This policy covers SelimReviewer only. The Modern Miracle website privacy notice covers visits to the rest of modern-miracle.com.

2. Whose data this policy covers

3. Google user data

This section states which data SelimReviewer receives from Google, and how it uses, stores, shares, protects and deletes that data.

3.1 Permissions SelimReviewer requests

When a person at a business connects a Google account, Google asks that person to grant two permissions:

Permission (OAuth scope)What SelimReviewer does with it
Manage your Business Profile (https://www.googleapis.com/auth/business.manage)Lists the Business Profile accounts and locations the Google account can manage. Reads the reviews of the locations the business selects. Reads the account's role on each location, to confirm that the person may act for it. Publishes replies the business approves, and removes a published reply when the business asks. Registers notifications of new reviews for the account.
See your primary Google account email address (email)Records who connected the account. Enables Google's Cross-Account Protection security alerts, so that SelimReviewer stops acting for an account that Google reports as compromised or whose access was revoked.

SelimReviewer does not create, edit or verify Business Profile listings, and does not use posts, photos, or questions and answers. It does not request any other Google permission.

3.2 Data SelimReviewer receives

3.3 How SelimReviewer uses it

SelimReviewer uses Google user data only to provide the features the business sees and uses in the service:

SelimReviewer does not use Google user data for advertising, does not sell it, does not use it to assess creditworthiness or for lending, and does not use it to develop, improve or train AI or machine-learning models, including generalised models. The AI providers that draft replies are contractually barred from training on it (section 3.5).

3.4 Who reads it

Authorised users of the business read reviews and drafts in the approval queue, which is the purpose of the service. MM staff read review or reply content only:

3.5 Who receives it

RecipientRoleWhat it receivesWhere
Microsoft (Microsoft Azure)Our processor: hosting, database, storage and messagingAll data in section 3.2Azure region Sweden Central (EU), inside the Microsoft EU Data Boundary
Microsoft (Azure AI Foundry, EU Data Zone deployments of models from Mistral AI, OpenAI and DeepSeek)Our processor: AI models that classify reviews, draft replies and check draftsReview text and reply drafts, in promptsEU Data Zone; no training on inputs
Google Cloud (Pub/Sub)Our processor: delivery of Business Profile notificationsNotification messages with identifiersEU message storage
Cloudflare, Inc.Our processor: network security and delivery for the appData shown to users in the app passes through Cloudflare encrypted to it, and Cloudflare decrypts it to screen it for attacksCloudflare data centre that receives the connection, which can be outside the EU/EEA (section 7)
The business's own AI model provider (Enterprise plans with bring-your-own-key only)Model provider the business chooses and contracts withReview text and reply drafts, in promptsAs recorded for that business in the subprocessor list or its Enterprise order form
GoogleThe platformReplies the business publishesGoogle

We also disclose data to authorities or courts where the law requires it, and to a successor if the SelimReviewer business is transferred, under the same protections and with the notice the law and Google's policies require. We do not transfer Google user data to anyone else.

3.6 Storage, retention and deletion

3.7 Disconnecting and revoking access

A business administrator can disconnect a Google account or a location in the SelimReviewer account settings. A Google account holder can also remove SelimReviewer's access at any time on the Google Account page "Third-party apps and services" (https://myaccount.google.com/connections). When a connection ends, SelimReviewer revokes its Google access, deletes the tokens and removes its notification registration within seven business days, and stops publishing for the affected locations. Review content already stored is deleted at its 28-day limit, or earlier on the business's instruction.

3.8 Protection

Google user data is encrypted in transit and at rest. Review and reply text is stored in encrypted fields under a key per review, and OAuth tokens are held in Azure Key Vault and never in source code. Access to the service requires multi-factor authentication for every customer account, and MM staff access to production data is limited to named people and logged.

3.9 Limited Use

SelimReviewer's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

4. Other data we collect

CategoryExamplesSource
Identity and contactName, business email, role, business nameThe user, or the administrator who invites the user
AuthenticationSign-in identifiers, multi-factor authentication data, session dataThe user, through our identity provider (Microsoft Entra External ID, in an external tenant located in Europe, where Microsoft stores most identity data in Europe)
Account activity, for securitySign-ins and the actions a user takes (approve, edit, reject, change settings, activate the kill switch), with timestampsGenerated when the service is used
Consent copyUser identifier, consent text version, time, locations and autonomy level coveredThe user, when giving consent for automatic replies on behalf of the business
BillingCompany details, VAT number, billing contact, payment status. Stripe collects card data; we do not receive full card numbersThe customer and Stripe
CommunicationsSupport requests and our replies, email delivery statusThe sender and our email provider
TechnicalIP address, browser and device information, logsGenerated when the service is used

5. Why we use it and our legal basis

PurposeLegal basis (GDPR)
Provide the service to the business: accounts, access, roles, notificationsArt. 6(1)(f), our and the business's legitimate interest in performing the contract; Art. 6(1)(b) where the user is the contracting party
Keep a copy of consent records for automatic replies, which Google's policies requireArt. 6(1)(f), showing compliance with platform policies and defending claims
Secure the service, detect misuse, investigate incidentsArt. 6(1)(f)
Bill, invoice and keep accounting recordsArt. 6(1)(b) or (f) as above; Art. 6(1)(c) for records the law requires
Send service and safety messages (security, billing, changes to terms and subprocessors). These are always sent, whatever the person's marketing choiceArt. 6(1)(f)
Send product news to business contacts who opted in. No marketing email is sent without an explicit opt-inArt. 6(1)(a), consent, which can be withdrawn through the link in each email
Answer support requestsArt. 6(1)(f)

For personal data in reviews and replies, the business that uses SelimReviewer is the controller and MM processes it on the business's behalf under a data processing agreement. Section 3 describes that processing for Google's purposes. Where we rely on legitimate interests, a data subject can ask us for details of the balancing test.

6. Who receives other data

Subprocessors (as of 2026-11-04)

MM uses the following subprocessors for SelimReviewer. MM gives business customers at least 30 days' notice of a new or replaced subprocessor, and a customer may object as the data processing agreement provides (terms clause 9.4).

SubprocessorServiceDataLocationTransfer basis
Microsoft (Microsoft Azure)Hosting, database, storage, messaging, key management, identity (Microsoft Entra External ID) and service email (Azure Communication Services Email)All SelimReviewer data in sections 3.2 and 4Azure region Sweden Central (EU), inside the Microsoft EU Data Boundary; Entra External ID tenant located in EuropeProcessing in the EU; limited transfers that Microsoft documents for the EU Data Boundary
Microsoft (Azure AI Foundry, EU Data Zone)AI models from Mistral AI, OpenAI and DeepSeek that classify reviews, draft replies and check draftsReview text and reply drafts, in promptsEU Data ZoneProcessing in the EU; no training on inputs
Cloudflare, Inc.Network security and delivery for the appData passing between users and the app, which Cloudflare decrypts to screen for attacksThe Cloudflare data centre that receives the connection, which can be outside the EU/EEAEU-US Data Privacy Framework; standard contractual clauses
StripePaymentsBilling data; Stripe collects card dataEU and United StatesEU-US Data Privacy Framework or standard contractual clauses
Google (Google Cloud Pub/Sub)Delivery of Business Profile notificationsNotification messages with identifiersEU message storageProcessing in the EU

Google, through Google Business Profile, is the source of the reviews and the recipient of the replies a business publishes. It acts under its own terms with the business and is not MM's subprocessor. On Enterprise plans with bring-your-own-key, the business's own model provider is recorded for that business in its Enterprise order form.

7. Transfers outside the EU/EEA

We store and process SelimReviewer data in an Azure EU region. Microsoft stores and processes data of its EU Data Boundary services in the EU/EFTA, with limited transfers that Microsoft documents. Every connection to the app passes through Cloudflare, a US company, which decrypts it to screen it for attacks and forwards it to our servers, at the Cloudflare data centre that receives the connection. That data centre can be outside the EU/EEA. Stripe can transfer data to the United States. Cloudflare, Inc. is certified under the EU-US Data Privacy Framework. Such transfers rely on the EU-US Data Privacy Framework (Commission Implementing Decision (EU) 2023/1795) for certified recipients, or on the European Commission's standard contractual clauses. A data subject can ask us for a copy of the relevant safeguards.

8. How long we keep other data

DataRetention
Identity and authentication data30 days after the user is removed from the account, or after the account's exit periods end
Our copy of consent records3 years after the last automatic reply the consent covered
Records of requests we forwarded to a business3 years after the request is closed
Invoices and accounting records7 years from the end of the financial year, as the Estonian Accounting Act requires, plus at most 12 months
Billing contact data not in invoices30 days after the account's exit periods end
Support communications24 months after the request is closed
Security logs90 days, or longer under a documented legal hold for a named incident, claim or authority request
Telemetry30 days
Service-email delivery records90 days
Marketing contact dataUntil the person withdraws consent (we then keep only a suppression entry), or 24 months after our last contact

9. Rights

Under the GDPR, a data subject has the right to access their data, to have it corrected or erased, to restrict its processing, to data portability, and to object to processing based on legitimate interests, including at any time to direct marketing. Where we rely on consent, it can be withdrawn at any time without affecting earlier processing. Requests go to hello@modern-miracle.com. We answer within one month, which we can extend in the cases the GDPR allows.

Some data in a business account belongs to the business's records: a user's role, approvals and edits, the business's consent and authority records, and its audit log. The business is the controller of those records and decides requests about them. If such a request reaches us, we forward it to the business within two business days.

Every data subject has the right to lodge a complaint with a supervisory authority, in particular in the EU country where they live or work or where an infringement took place. Our lead authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), https://www.aki.ee/en.

10. Automated decisions

We do not make decisions about account users based solely on automated processing that have legal or similarly significant effects on them. Stripe can use automated fraud screening for payments, as described in Stripe's own privacy notice.

11. People who wrote a review

If a business uses SelimReviewer to answer reviews, the business decides how the review is processed and is responsible for that processing. We process the review and the reply on the business's behalf and keep review text for at most 28 days (section 3.6). Reviewers can contact the business to exercise their rights. If a reviewer contacts us, we forward the request to the business within two business days and, where the reviewer objects, we pause processing of the matching review until the business decides.

12. Changes

We update this policy when our processing changes, and show the date of the current version at the top. We notify business customers of material changes in the account and by email.

13. Contact

Modern Miracle OÜ, Tornimäe tn 5, 10145 Tallinn, Harju County, Estonia. Privacy: hello@modern-miracle.com. Support: hello@modern-miracle.com.