Last updated: 5/18/2026. This policy describes how Crew Orbit (https://crew-orbit.com) processes personal data in connection with the service as implemented today. The legal entity named in our Legal Notice is the controller for this offering.
This policy covers the Crew Orbit web application, API, and related background processing (including AI-assisted workflows). Where we integrate third-party processors (cloud hosting, authentication, payments, AI providers), their processing is described below.
For our own website, account, billing, and service operations, Forge Labs UG acts as the controller. For customer content processed on behalf of team organizations (for example task content, repository context, prompts, attachments, and generated outputs within a workspace), we generally act as a processor and the customer organization acts as the controller. Our Data Processing Agreement (DPA) is available for business customers.
Key GDPR legal bases include:
Our legitimate interests under Art. 6(1)(f) GDPR include securing the service, preventing abuse, investigating incidents, and ensuring reliable operation for all customers.
Where additional laws apply, we rely on the corresponding legal basis required for the relevant processing activity.
Deployed environments are hosted on Amazon Web Services (AWS), with the primary region EU (Frankfurt), AWS region eu-central-1 for infrastructure as defined in this product's deployment configuration.
Major storage components include:
Third-party AI providers (for example providers supported by the product such as Anthropic, OpenAI, Cursor, or GitHub Copilot) may process prompts and code context outside our AWS account, under their own terms and locations. In the current product design, the AI provider used for a workspace is determined by credentials and settings configured by the customer in that workspace; we do not currently supply a separate proprietary default model on your behalf.
Where personal data is transferred outside the EEA/UK/Switzerland, we rely on an appropriate transfer mechanism such as an adequacy decision or the European Commission's Standard Contractual Clauses (SCCs), together with supplementary measures where required.
Account deletion: You can request deletion from account settings. The account enters a deleting state; a background job cancels active work, transfers or deletes projects you own (per your choices), removes memberships, deletes feedback and related images, removes or winds down organizations as applicable, deletes your avatar object, and marks the account deleted. A scheduled job permanently removes accounts that have been in the deleted state for longer than the configured grace period (default 14 days), including deletion of the identity record in Cognito. During the grace period you may be able to restore the account where the product allows it.
Data export: The in-product export includes profile, project memberships (with project names and roles), and your feedback records. It does not include other users' data, full project/task content, credentials, or detailed AI run outputs — those may require separate procedures.
Project deletion: Deleting a project removes associated tasks, run / execution records, project settings, project memberships, and stored credentials for that project from our databases. Deleting an individual task triggers cleanup of attachments tied to that task in object storage.
Team organization deletion: Deleting a team organization (where the product allows it) removes its projects and related data, organization settings, org-level credentials, roles, memberships, and subscription records from our application database.
Attachments: Attachment records may include time-limited metadata for failed or transient states (automatic expiry in DynamoDB). Optimized extracts and originals persist until removed by user/project lifecycle actions or operational cleanup consistent with the above.
Operational logs: Routine application and infrastructure logs are typically retained for 30 days in non-production environments and up to 90 days in production, unless a longer period is required to investigate abuse, security incidents, or legal claims.
Queue metadata: Certain asynchronous processing records (for example queue retention windows) may persist for up to 14 days before expiry or cleanup.
Backups and recovery: Some production data stores use AWS point-in-time recovery or similar backup features while active. Backup copies and recovery points may persist for a limited period beyond primary deletion, subject to cloud-provider controls and operational necessity.
Current categories of recipients and subprocessors include:
We maintain a public subprocessor list at /subprocessors and may update it as our infrastructure and integrations evolve.
Depending on your jurisdiction (including GDPR where applicable), you may have rights to access, rectify, erase, restrict or object to certain processing, and to data portability, and to lodge a complaint with a supervisory authority. If our establishment in Lower Saxony, Germany is relevant to your complaint, you may also contact the Landesbeauftragte für den Datenschutz Niedersachsen. Use the contact below first where possible; we may need to verify your identity.
We use browser local storage for essential product functions — for example keeping your session tokens (via the app's auth store) and UI preferences such as theme (light/dark). These are not used for third-party advertising in the product implementation described here. Additionally, Stripe may set essential cookies necessary for payment processing and fraud prevention; these do not require consent.
We process your prompts, codebase context, and files to provide the AI engineering service. Our policy regarding AI data is as follows:
The service is intended for professional use and is not directed at children. We do not knowingly collect personal data from children under 16.
Privacy and data protection inquiries: info@crew-orbit.com.
We do not currently designate a formal Data Protection Officer unless and until legally required, but privacy requests sent to this address are routed to the responsible team.
This policy summarizes technical behavior reflected in the product codebase and infrastructure. It is not legal advice. Final wording should be reviewed by qualified counsel, especially for enterprise customers, DPAs, and jurisdiction-specific obligations.
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