Last updated: 8/17/2026. 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, code context, knowledge embeddings, and retrieved passages outside our AWS account, under their own terms and locations. Knowledge embeddings and retrieved passages are sent to the customer-configured AI endpoint (OpenAI-compatible, including Azure OpenAI, LiteLLM, or a self-hosted endpoint). That endpoint may process data outside our AWS account and outside the EEA. 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 supply a platform-owned 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. That request marks the account as deleting and records the request time. Workspace data stays in place during a grace period (default 14 days). While the account is still in the deleting state and inside that window, you can restore it from account settings. After the grace period, a daily job (default 03:00 UTC) cancels active work on projects you own, then permanently deletes: projects you own that were not transferred, your memberships, your feedback and related images, your personal organization, a team organization only if you were the last member (otherwise your membership is removed), your notifications, linked Slack identity, MCP personal access tokens, your avatar object, your user record, and your Cognito identity. Restore is not available after that hard delete.
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 is immediate. There is no restore window. It removes associated tasks, run and execution records, project settings, project memberships, invitations, stored credentials, project rooms, project-scoped Crew Guidance, project knowledge library documents (including saved conversation notes and related S3 objects), task attachments in object storage (originals and optimized extracts), and run artifact objects for that project.
Team organization deletion: Deleting a team organization (where the product allows it) is immediate. There is no restore window. Personal organizations cannot be deleted this way. Team organization delete removes its projects (same cascade as project deletion), organization settings, org-level credentials, roles, memberships, subscription records in our application database, remaining workspace-scoped knowledge, Crew Guidance at organization scope, and knowledge retrieval-audit records for that organization. The Stripe customer object may remain with Stripe for billing and tax after the local subscription row is removed.
Ask sessions: Conversational Ask sessions, messages, and related approvals expire by time-to-live (typically about 7 days). Account or workspace deletion does not wait on that expiry and does not claim to wipe those rows immediately.
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, or organization 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 run-queue and provider-lane rows) may persist for up to about 7 days before expiry when they are not removed as part of a project cascade.
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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