Cookie Policy for AI Assistants

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This policy explains how cookies and similar technologies are used within the AI assistants provided by Chapter Holding B.V. These technologies support secure operation, consent management, anonymous analytics, and essential product functions. Cookies that are not strictly necessary are only activated after you provide consent. You can withdraw that consent at any time.

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1. About us

Controller: Your organization when deploying a Chapter AI assistant
Processor: Chapter Holding B.V.
Address: Fred Roeskestraat 115, Amsterdam, The Netherlands
Email: info@chapter.works

When Chapter provides embedded AI assistants, we act as a data processor and follow GDPR requirements for processors as described in the internal privacy framework .

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2. What are cookies

Cookies are small data files stored in your browser. The assistant may also use local storage and session storage. These technologies allow the assistant to enforce consent, manage sessions, store chat history identifiers, and run minimal analytics features depending on the consent you provide.

Strictly necessary technologies are always active because the assistant cannot function without them.

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3. How we use cookies

We classify technologies into the following categories.

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Strictly necessary

These technologies are required for the assistant to work securely and cannot be disabled.

Used for:

• Enforcing cookie consent before the user can send questions
• Generating and storing an anonymous user ID so the assistant can show chat history and manage anonymous sessions
• Core session management, application state, and security tokens
• Storing and validating consent records in compliance with GDPR Article 7, including timestamp and IP

Chat is not possible without necessary cookie consent.

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Functional

These technologies allow the assistant to remember UI preferences and improve your experience. May be used for:

• Saving interface or language preferences
• Remembering collapsed or expanded elements in the assistant UI

Chat is not possible without functional cookie consent.

Analytics

Only used after explicit consent. Used for:

• Measuring basic assistant usage such as number of questions per anonymous user, returning vs new users, and high level distribution insights
• Anonymous product analytics to support system reliability and performance metrics
  
  
• Supporting customer support cases when you voluntarily submit contact information such as name, email, or phone number to create a ticket
  
  

Analytics do not include third party advertising cookies. The assistant does not use advertising or marketing cookies. Chat is not possible without analytics cookie consent.

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Marketing and advertising

Not used by the AI assistant. No third party advertising technologies run inside the assistant environment.

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4. Technologies we use

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Strictly necessary

Consent storage
Stores your consent state, including the consent ID used to associate chat history with your device.
Environment: Assistant
Retention: Local storage until consent is withdrawn

Anonymous user ID
Stores a random identifier used to provide chat history for anonymous users.
Environment: Assistant
Retention: Local storage until deleted by the user via settings or consent withdrawal

Session and security tokens
Support secure assistant operation and prevent unauthorized access.
Environment: Assistant
Retention: Session or short term persistent

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Functional

UI and language preferences
Allows the assistant to remember language or interface choices.
Environment: Assistant
Retention: Varies

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Analytics

Anonymous usage analytics
Used to track basic usage patterns using anonymous user IDs, including question frequency and broad patterns such as employee vs customer usage distributions.
Environment: Assistant
Retention: Varies, controlled by the client and their analytics environment

Consent logs
Stored server side to meet GDPR requirements.
Environment: Server
Retention: According to client policy and GDPR requirements

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Marketing

Not applicable.

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5. Legal basis

Strictly necessary technologies rely on our legitimate interest in ensuring the assistant works securely and reliably.
Analytics and any non essential technologies rely on your explicit consent, which is requested through the assistant’s consent banner before you can submit questions.

Consent is stored with timestamp and IP, and you can withdraw it at any time.

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6. Managing your preferences

You can manage your consent directly within the assistant. Options include:

• Accept all
• Reject all
• Customize your choices
• Withdraw consent at any time

Withdrawing consent:

• Deletes your chat history that was associated with your consent ID
• Removes cookies and local storage keys
• Reopens the consent banner before further use of the assistant
  
  

7. Your rights

You have rights under GDPR including access, erasure, objection, restriction, and portability. Since the assistant may operate under your organization’s control, your organization acts as the data controller and is responsible for fulfilling these rights, while Chapter acts as processor in accordance with GDPR requirements.

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8. Changes to this policy

We may update this cookie policy from time to time. The latest version will always be accessible in the assistant interface.

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9. Contact

For privacy and compliance questions: info@chapter.works

• Privacy team: privacy@chapter.works
• DPA requests: dpa@chapter.works
• Security incidents: security@chapter.works (available 24/7)
• Data subject requests: dsr@chapter.works
  
  

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