Privacy notice
Last updated: October 2026
Who we are
bnlCRM is a service of Blue Note Logic Inc., a Wyoming corporation with its corporate office in Raleigh, North Carolina, USA ("Blue Note Logic", "we"). We are the controller of the personal data described in this notice. You can reach us at hello@bnlcrm.com.
Our representative in the EEA under GDPR Art. 27 is David John Gilligan, Kapermoen 6b, 3612 Kongsberg, Norway. You can also write to our representative about anything in this notice.
What this notice covers
This notice covers messages you send to the bnlCRM Assistant on Telegram (@bnlcrm_bot), the waitlist form on bnlcrm.com, emails you send to hello@bnlcrm.com, and visits to bnlcrm.com.
Messages to the bnlCRM Assistant
What we keep
- Your Telegram user ID, which we need to send our replies to you.
- The name shown on your Telegram profile.
- The text of your messages and of our replies, stored encrypted.
- When each message was sent, and whether you asked to stop messages or to talk to a person. A request to stop messages is recorded against a keyed hash of your Telegram ID, so that we keep honouring it.
- Photos, files and voice messages are not processed. We keep only a note that one was sent.
- Telegram's delivery record of each message, kept encrypted for 72 hours so that we can process it reliably, and then deleted.
Why, and on what legal basis
We use this information to answer your questions about bnlCRM and Blue Note Logic, to pass your conversation to a person when needed, and to respect your choice to stop messages. Our legal basis is our legitimate interest in answering the enquiries people send us (GDPR Art. 6(1)(f)) and, where you ask about using bnlCRM, steps you ask us to take before a contract (Art. 6(1)(b)). Keeping your opt-out is necessary so that we do not contact you again (Art. 6(1)(f)).
How the AI is used
An AI model drafts each reply. It works only from Blue Note Logic's approved public information about bnlCRM and from your own conversation, never from other people's conversations. It receives the conversation text and the name on your Telegram profile, not your Telegram IDs. A person at Blue Note Logic reviews, edits or rejects each draft before anything is sent, so no decision about you is made automatically. We tell you at the start of each conversation that you are talking with an AI. We do not use your conversations to train AI models.
Leads in our CRM
If you ask for a demo, a call or another follow-up, a person at Blue Note Logic may create a record in our CRM with the details you gave us in the chat, such as your name, company and email address, and a short summary. A person approves each record before it is created.
The waitlist
When you join the waitlist, we keep your name, work email, company, what you would use bnlCRM for, your consent choices and when you made them, and a keyed hash of your IP address that we use to stop abuse of the form.
We use these details to contact you about early access, based on your consent (GDPR Art. 6(1)(a)). If you also tick the news box, we send you occasional news, based on that consent. You can withdraw your consent at any time by writing to hello@bnlcrm.com.
Your sign-up is stored in Blue Note Logic's lead database and in our CRM, both on our own servers. We send you one confirmation email when you sign up.
Emails to hello@bnlcrm.com
A person at Blue Note Logic reads and answers them. They are stored on our own mail server in Germany. Our legal basis is our legitimate interest in answering you (Art. 6(1)(f)), or steps you ask us to take before a contract (Art. 6(1)(b)).
Visiting bnlcrm.com
bnlcrm.com sets no cookies and loads nothing from other companies: no analytics, no advertising or tracking, and no externally hosted fonts. Our web server keeps standard access logs (IP address, time, page requested and browser type) for security, and deletes them after 30 days.
Who processes your data for us
- Hetzner Online GmbH (Germany) hosts our servers in Germany and Finland.
- Amazon Web Services EMEA SARL (Luxembourg) runs the AI model (Anthropic's Claude, through Amazon Bedrock) in AWS's EU region in Ireland. The content is not used to train models.
- Telegram delivers the messages between you and the assistant. Telegram processes them under its own privacy policy (https://telegram.org/privacy), as a service you chose to use.
When WhatsApp support launches, we will add Meta here before it is switched on. We do not sell your data or share it for advertising.
Transfers outside the EU
Your data is stored and processed in the EU. Blue Note Logic Inc. is a US company, so people at Blue Note Logic may access it from outside the EU to answer you and to run the service. Amazon Web Services EMEA SARL is part of a US group that participates in the EU-US Data Privacy Framework.
How long we keep it
- A Telegram conversation closes 30 days after your last message. Its message text is deleted 180 days after it closes.
- Telegram delivery records: 72 hours.
- If you asked us to stop messages, we keep that opt-out for 3 years, even if you ask us to delete your other data, so that we do not contact you again.
- Telegram contacts that are not linked to a CRM record are deleted after 12 months without activity.
- Records of who approved what, without any message text, are kept for 2 years.
- CRM records created at your request: for as long as we are in contact, and no longer than 24 months after our last contact, unless you ask us to delete them sooner.
- Waitlist sign-ups: until we open access for you or you ask to be removed, and no longer than 24 months after you signed up.
- Emails: as long as needed to answer you, and no longer than 24 months after our last exchange.
- Web server logs: 30 days.
Your rights
You can ask for a copy of your data, ask us to correct or delete it, object to our use of it or ask us to restrict it, and receive it in a portable format where the law provides for this. Where we rely on your consent, you can withdraw it at any time. Write to hello@bnlcrm.com. We answer within one month.
On Telegram, write STOP (or /stop) to stop messages, and HUMAN to reach a person.
You can also complain to a data protection authority, for example the one in the EU or EEA country where you live or work.
Changes to this notice
When we change how we handle personal data, we update this page and the date at the top.