Privacy policy
Last updated: 20 October 2026
Who we are
Tonka is an AI assistant: her replies are written by artificial intelligence. The service is provided by DOT LAMBDA d.o.o., Gašpina mlinica 10, 21231 Klis, Croatia, OIB 63946805743. We are responsible for your personal data, as the controller under the EU General Data Protection Regulation (EU) 2016/679 («GDPR»). For any privacy question, write to info@tonka.hr.
What we process
- messages you send Tonka on Telegram or WhatsApp: text, voice messages and their transcripts, photos and documents;
- email you forward to tonka@tonka.hr;
- notes Tonka keeps about people, companies and topics you mention;
- your account details: name, login addresses, phone number and settings.
If you connect Outlook or Google Calendar
- a copy of your calendar (up to about two months back and 13 months ahead), including attendees' names and email addresses, so Tonka can plan, warn you about clashes and prepare your daily overview;
- the names and email addresses of people on your meetings, with the title and date of the last meeting they were on, so Tonka can find someone's address when you invite them to a meeting. To do this, Tonka reads your meetings from the past 12 months once, and keeps only people from meetings you organised or accepted. Each such entry is deleted 12 months after that last meeting;
- appointments Tonka creates or changes at your request, and invitations sent from your account after you confirm them;
- your contacts, and on Google also the addresses Google saves from your email («Other contacts»), only when you invite someone. Tonka searches them at that moment and doesn't store your contact list, but remembers the address you confirm for that person;
- when you ask for a time that suits others too, when the people you name are free or busy, as far as their calendar shows you that. Tonka reads it at the moment you ask and doesn't store it, apart from the times she suggests to you, and never sees the details of their meetings;
- access tokens, which we store encrypted.
You disconnect a calendar in the portal, under «Connected calendars», or by typing /kalendar odspoji in your chat with Tonka. We then delete the calendar copy, the people remembered from your meetings, and the tokens, and for a Google account we also revoke Tonka's access at Google. You can also revoke access yourself, in your Microsoft or Google account settings.
Why we process data, and on what basis
The GDPR allows personal data to be processed only on one of the grounds listed in its Article 6. We rely on two:
- Your data is processed because it is needed for the service you asked for and use. (GDPR Art. 6(1)(b): processing necessary for the performance of a contract, here the service you use)
- Data about other people you mention, or who are on your meetings, is processed only as far as that service needs, because that is in your and our legitimate interest. (GDPR Art. 6(1)(f): legitimate interests)
- Technical traces of AI model calls are kept to fix problems and for security, also on the basis of legitimate interest. (GDPR Art. 6(1)(f))
Who processes data for us
Some providers are outside the European Union. The GDPR allows such a transfer when the European Commission has adopted an adequacy decision for that country (Art. 45), or when the Commission's Standard Contractual Clauses are in place (Art. 46). The basis for each provider is in the table.
| Provider | For | Where | Transfer basis |
|---|---|---|---|
| OpenAI | AI model that reads your requests and writes every one of Tonka's replies, receiving the messages and calendar data needed to answer | US | Standard Contractual Clauses (GDPR Art. 46) |
| Anthropic | backup AI model, which writes replies only when OpenAI is down or doesn't answer in time | US | Standard Contractual Clauses (GDPR Art. 46) |
| Gemini turns your voice messages into text and reads Tonka's replies aloud, and a reply it reads may mention a meeting's title | US | EU-US Data Privacy Framework, adequacy decision (GDPR Art. 45) | |
| Microsoft | our mailbox tonka@tonka.hr, where you forward mail to us | EU | data processing agreement (GDPR Art. 28) |
| Meta | US | EU-US Data Privacy Framework, adequacy decision (GDPR Art. 45) | |
| Cloudflare | network and connection security | global | EU-US Data Privacy Framework, adequacy decision (GDPR Art. 45) |
| Hetzner | servers that hold your data | Germany | no transfer outside the EU |
AI providers don't use your data to train their models. They may keep requests briefly, usually up to 30 days, to prevent abuse.
Telegram
If you use Tonka through Telegram, Telegram is a channel you chose yourself. Telegram is an independent controller of its own data, and its own privacy policy applies.
Your Microsoft or Google account
If you connect Outlook or Google Calendar, your calendar and contacts stay in your own Microsoft or Google account, which you chose yourself. Your own terms with that provider and its privacy policy apply to them, and for a work or school account your organisation's rules too. Tonka reads and changes data there only with your permission and only as far as the service you use needs, so Microsoft and Google don't process that data for us. What Tonka keeps of it, as described above, we hold on servers in Germany.
Data from your Google account
Tonka'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. We use Google account data only for the features described above, and send it to AI providers only so Tonka can answer your request. We don't use it for advertising, don't sell it, don't use it to determine creditworthiness, and don't use it to develop or train general AI models.
Who on our side sees your data
We look at your messages, notes and calendar data only when we need to fix a fault in the service or protect its security, and for no other reason.
How long we keep data
- while your account exists;
- people remembered from your meetings are deleted 12 months after the last meeting they were on;
- technical traces of AI model calls are deleted after 60 days;
- backups are kept for 7 days.
If you want us to delete all your data, write to info@tonka.hr and we will delete it within 30 days. Remaining copies leave the backups within 7 days and the technical traces within 60 days.
Your rights
Under the GDPR you have the right to access your data, and to correction, deletion, restriction of processing, data portability and objection (Arts. 15–21). Send requests to info@tonka.hr. You also have the right to lodge a complaint with the Croatian Personal Data Protection Agency (Art. 77): AZOP, azop.hr.