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Privacy Policy

Masterly Ltd.

Effective Date: December 16, 2025

1. Introduction

This Privacy Policy describes how Masterly Ltd. ("Masterly", "we", "us", or "our") collects, uses, stores, and discloses information in connection with the provision of our business-to-business software-as-a-service platform (the "Service").

Masterly provides services that analyze communications between our customers and their end customers in order to generate insights. Our customers act as data controllers with respect to any personal data contained in such communications, and Masterly acts as a data processor unless expressly stated otherwise.

2. Scope

This Privacy Policy applies to:

  • Business customers using the Service
  • Data processed on behalf of our customers in the course of providing the Service

This Privacy Policy does not apply to end users of our customers, except to the extent their data is processed on behalf of our customers.

3. Information We Process

3.1 Customer Account Information

We process information provided by our customers when creating and administering accounts, including:

  • Company name
  • Business contact details
  • Billing and administrative information

3.2 Customer Content

In the course of providing the Service, we process communications between our customers and their end customers ("Customer Content"). This may include personal data if such data is contained in those communications.

Customer Content is processed solely for the purpose of providing, maintaining, and improving the Service in accordance with our contractual obligations.

3.3 Usage and Technical Data

We may collect limited technical and usage data, including:

  • Log data
  • IP addresses
  • Device and browser information
  • Performance and diagnostic metrics

4. Purpose of Processing

We process information strictly for the following purposes:

  • Providing and operating the Service
  • Analyzing Customer Content to extract insights as instructed by our customers
  • Ensuring security, reliability, and performance
  • Meeting legal and regulatory obligations

We do not use Customer Content to train our own models or for unrelated purposes.

5. Service Providers and Subprocessors

Masterly Ltd. engages a limited number of third-party service providers ("Subprocessors") to support the operation and delivery of the Service. These providers process data solely on our instructions and subject to contractual confidentiality and data protection obligations.

Infrastructure and Platform Services

  • Amazon Web Services (AWS) – cloud infrastructure and hosting
  • Cloudflare – content delivery, security, and DDoS protection
  • PlanetScale – database hosting
  • Convex – database and application backend services

Identity and Access Management

  • WorkOS – authentication, enterprise SSO, and identity management

Error Monitoring

  • Sentry – error tracking and application monitoring
    (May process technical metadata such as IP addresses and request-related identifiers.)

AI Model Providers

Customer Content is exposed to AI model providers solely for the purpose of delivering AI-driven functionality within the Service.

  • xAI (Grok) – default AI model provider

At the customer's explicit configuration and direction, Customer Content may additionally be processed by:

  • OpenAI (ChatGPT)
  • Anthropic
  • Moonshot

Masterly does not independently disclose Customer Content to these providers; processing occurs only as a direct result of customer-selected settings.

6. Data Sharing and Disclosure

We do not sell, rent, or otherwise disclose Customer Content to third parties except:

  • As necessary to provide the Service
  • To authorized subprocessors under contractual confidentiality and data protection obligations
  • Where required by law or valid legal process

7. Data Training and Model Use

Masterly does not:

  • Train its own models on Customer Content
  • Permit use of Customer Content for training by subprocessors beyond what is contractually necessary to provide the Service

8. Data Retention

Customer Content is retained only for the duration specified in our agreements with customers or as required to provide the Service. Data may be deleted or returned upon customer request, subject to legal and contractual requirements.

9. Security

We implement appropriate technical and organizational measures to protect data against unauthorized access, loss, or disclosure, including encryption, access controls, and network security measures.

10. International Data Transfers

Customer Content may be processed in jurisdictions where our service providers operate. Where required, we rely on appropriate safeguards, including standard contractual clauses or equivalent mechanisms.

11. Customer Responsibilities

Our customers are responsible for:

  • Ensuring they have a lawful basis to provide Customer Content to Masterly
  • Informing their end customers about applicable data processing
  • Responding to data subject requests related to Customer Content

12. Data Subject Rights

Requests relating to personal data contained in Customer Content should be directed to the relevant customer (data controller). Masterly will assist customers in fulfilling such requests where required by law.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through appropriate channels.

14. Contact Information

For privacy-related inquiries, contact:

Masterly Ltd.
Email: mi@masterli.io
Address: 77 East Road, London, England, N1 6AH