Contents — 12 sections
- Scope and definitions
- 1. What a sub-processor is, in plain English
- 2. How Ingy handles your content, briefly
- 3. The complete list of sub-processors and providers
- 4. Who actually sees your content, and who does not
- 5. Creem is a separate controller
- 6. Telegram is the platform, not a vendor we chose for you
- 7. International transfers
- 8. We do not sell your data
- 9. Changes to this list — 30 days' notice
- 10. Contact
- Contact
Scope and definitions
General and privacy contact: [email protected]
In this page, "we", "us" and "our" mean IX Labs. "You" and "your" mean the person using our product.
Our product is Ingy, a Telegram bot that drafts social media posts from a link, a video, or plain instructions. Our website is ingy.app and the bot is @IngyAppBot.
This page stands on its own. You do not need to read any other document to understand who processes data on our behalf and what they receive.
1. What a sub-processor is, in plain English
1.1 To run Ingy we use other companies. Some of them handle your data on our instructions. Those companies are our sub-processors.
1.2 This page names all of them. The table in section 3 is the complete list as at the date at the top of this page. There are no others.
1.3 Where a company is not acting on our instructions but decides for itself how it uses data — for example our payment provider — we say so in the table, because that is a different relationship and you should know which is which.
2. How Ingy handles your content, briefly
You need this to make sense of the table.
2.1 Ingy runs entirely as a Telegram conversation. Your account is your Telegram account. There is no separate login.
2.2 You give Ingy a source: an article URL, a video link (YouTube, TikTok, Instagram, X), an uploaded video, or instructions on their own. Sources can be combined.
2.3 Articles are fetched. Video and voice are transcribed. A large language model then drafts a post, which is delivered to you as one copyable plain-text message.
2.4 A style profile is learned from your finalised posts and is included in later prompts.
2.5 Ingy never publishes anything. Publishing is manual and is entirely your decision.
3. The complete list of sub-processors and providers
| Provider | What it does for us | What it receives | Sees your content? | Location |
|---|---|---|---|---|
| Anthropic — anthropic.com | AI text generation. Writes your drafts. | Your prompts, your sources, your instructions, your style profile, and the generated output. | Yes — prompts and outputs | USA |
| OpenAI (Whisper) — openai.com | Audio transcription of voice messages and video audio. | The audio and the resulting transcript. | Yes — audio and transcripts | USA |
| Supadata — supadata.ai | Retrieves transcripts for video links. | Video URLs and the transcripts returned. | Partly — video URLs and returned transcripts | USA |
| Firecrawl — firecrawl.dev | Fallback fetching of article pages when direct fetching fails. | Article URLs and the fetched page text. | Partly — article URLs and fetched page text | USA |
| Langfuse — langfuse.com | LLM tracing and cost analysis. Lets us debug and price model calls. | Traces of model calls, including the full prompt and output text, keyed to a user ID. | Yes — prompts and outputs, keyed to a user ID | EU cloud |
| PostHog — posthog.com | Two separate projects: product analytics (which features are used and where things break) and website analytics (anonymous traffic on our public website). | Counts, category values, durations and URL hostnames only; for the website, page addresses, referring site, browser and device type, and approximate location from the IP address. | No — no user content in either project | USA |
| Creem (Armitage Labs OÜ, Estonia) — creem.io | Merchant of Record. Sells Ingy subscriptions, processes payments and pays out refunds. | Your name, email, billing address and payment data. | No post content. Billing data only. | EU |
| WayForPay — wayforpay.com | Card acquiring for Ukrainian customers. Closed to new subscriptions. Still processes renewals and cancellations for customers who subscribed through it earlier. | Your email, the subscription reference and payment data. | No post content. Billing data only. | Ukraine |
| Telegram — telegram.org | The messaging platform Ingy runs on. | Your messages to and from the bot pass through Telegram. | Yes — messages pass through Telegram | Per Telegram's own terms |
| Hetzner Online GmbH — hetzner.com | Hosting. Runs our application servers and our PostgreSQL database. | All data we store: your posts, versions, style profile and account records. | Yes — all stored data | Germany |
4. Who actually sees your content, and who does not
This is the part people care about most, so we are stating it directly rather than leaving you to read the table.
4.1 Providers that receive your actual content:
- Anthropic — receives your prompts and returns generated output. This is the core of the product.
- OpenAI — receives audio you submit and produces transcripts of it.
- Langfuse — traces stored in Langfuse contain the prompt text and the output text, keyed to a user ID. We use this to debug bad drafts and to understand cost. We are naming this explicitly because "tracing" and "observability" sound like metrics tooling, and in this case it is not: it contains real content. Langfuse is hosted in the EU.
- Hetzner — as our hosting provider, holds everything we store, because our servers and database run there.
- Telegram — every message between you and Ingy passes through Telegram, because that is the platform the product runs on.
4.2 Providers that receive URLs and fetched material, but not your instructions or drafts:
- Supadata — receives the video URL you submitted and returns the transcript.
- Firecrawl — receives the article URL you submitted and returns the page text.
4.3 Providers that receive no content at all:
- WayForPay — receives your email, the subscription reference and payment data, for Ukrainian customers who subscribed before it closed to new subscriptions. It does not receive your posts, your sources or your style profile.
- PostHog — receives no user content whatsoever. No prompts, no drafts, no transcripts, no style profile. What it receives is counts, category values (which feature, which source type), durations, and the hostname of a URL — for example
bbc.co.uk, never the full article address. This is a deliberate design decision, not an accident.
4.4 Billing only:
- Creem — receives your name, email and billing and payment data. It does not receive your posts, your sources or your style profile.
5. Creem is a separate controller
5.1 Creem is the Merchant of Record for Ingy purchases, and is the contracting seller for the payment transaction. Creem is operated by Armitage Labs OÜ (registry code 16977866, Estonia). Creem processes payments and pays out the refunds we approve.
5.2 For payment and billing data, Creem acts as a separate and independent data controller, not as our sub-processor. It decides for itself how it handles that data, and it does so under its own terms and privacy policy at creem.io.
5.3 We include Creem on this page anyway, because you should be able to see everyone in the chain in one place.
6. Telegram is the platform, not a vendor we chose for you
6.1 Ingy runs inside Telegram. Your account is your Telegram account.
6.2 Every message you send to the bot, and every draft it sends back, passes through Telegram's systems and is subject to Telegram's own terms and privacy policy at telegram.org.
6.3 We do not control Telegram and we cannot change how it handles messages. If that matters to you, read their terms before using the bot.
7. International transfers
7.1 We are a UK company. Some of our providers are in the USA — Anthropic, OpenAI, Supadata and Firecrawl.
7.2 Where personal data is transferred from the UK or the EEA to a provider in the USA or another country without an adequacy decision, that transfer is made under the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, or equivalent safeguards offered by that provider.
7.3 Langfuse is hosted in the EU. PostHog is hosted in the United States. Hetzner hosts our servers and database in Germany. Creem operates in the EU. WayForPay operates in Ukraine.
8. We do not sell your data
8.1 IX Labs does not sell your data. We do not sell, rent or trade your posts, your sources, your style profile or your contact details to anyone.
8.2 The providers listed on this page process data to make the product work, on our instructions, and for no purpose of our choosing beyond that.
9. Changes to this list — 30 days' notice
9.1 Before we add a new sub-processor that will have access to your content, we will give at least 30 days' notice.
9.2 Notice is given by updating this page — including the version number and the "last updated" date at the top — and by emailing everyone who has subscribed to notifications under section 9.3.
9.3 To be notified, email [email protected] with "Sub-processor notifications" in the subject line. We will add you to the list. You can ask to be removed at any time the same way.
9.4 We may replace a provider more quickly where it is necessary for security or continuity of the service — for example if a provider fails or is compromised. Where that happens, we will update this page as soon as we can and explain what changed.
9.5 Adding a provider that receives no user content does not trigger the 30-day notice period, but it will still be added to the table on this page.
10. Contact
10.1 Questions about this page, or about who handles your data: [email protected].
10.2 Formal legal notices: [email protected], or IX Labs, 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom.
10.3 This page is governed by the law of England and Wales.
Contact
IX Labs
27 Old Gloucester Street, London, WC1N 3AX, United Kingdom
General enquiries: [email protected]
Legal notices: [email protected]