Last updated: May 18th, 2024

Please read this document carefully before accessing or using this service.

Introduction

Most Privacy Policy documents are unreadable. They are written by lawyers and for lawyers, and in our opinion are not very effective. Data protection and privacy are important, and we want you to understand the issues involved. For that reason we decided to use plain English instead as much as possible, to make our terms as clear as possible.

When you read 'the t2bot.io homeserver' or 'the Service' below, it refers to the services made available at https://t2bot.io which store your account and personal conversation history, provide services such as bots and bridges, and communicate via the open Matrix decentralised communication protocol with the public Matrix Network.

The public Matrix Network is a decentralised and openly federated communication network. This means that user messages are replicated on each participant's server and messages posted to a room are visible to all participants including in some cases any new joiners. This is further explained at 2.3.

Where you read The Matrix.org Foundation C.I.C., The Matrix.org Foundation, or The Foundation, it refers to the Community Interest Company incorporated on 29 October 2018 to be the neutral custodian of the Matrix protocol: The Matrix.org Foundation C.I.C., and their agents.

The Matrix protocol is licensed by the Matrix.org Foundation which makes it available to third parties who set up their own homeserver. This privacy policy does not apply to such Matrix servers run by anyone else - Matrix is an open network like the Web and this agreement only applies to the server (t2bot.io) sponsored by The Matrix.org Foundation C.I.C.

Travis Ralston is the Data Controller for the Service, and works with The Matrix.org Foundation C.I.C. and their agents as a Processor for data processing, hosting, and management purposes. The Foundation is additionally consulted on data privacy matters pertaining to t2bot.io, such as GDPR requests and general advice.

Travis Ralston can be contacted as per the details below:

Matrix: @travis:t2l.io

Email: travis@t2bot.io. Please note that email communication is often slower and can have upwards of a 5 business day delay.

Should you have other questions or concerns about this document, please let us know using the above communication methods.

This is a living document

This is a living document. With your help, we want to make it the best in the industry.

If you read something that rubs you the wrong way, or if you think of something that should be added, please get in touch! We're all ears! Reach out using the contact methods above. We don't amend this document for any specific users or use case, but if your proposed changes apply to all of our users, we'll be happy to update it for everyone. Scroll to the bottom to see the history so far.

We will likely improve this document over time and we will take steps to inform our users about any updates. By continuing to use the Service, you will implicitly accept the changes we make. If updates to this document are ever associated with significant changes to the way we collect our process your data, we will promptly notify you.

Your access and use of the Service is always subject to the most current version of this document.

Access to your data

Legal basis for processing

t2bot.io processes your data under a Legitimate Interest basis of processing, to provide our Service to you in an efficient and secure manner and to ensure the legal compliance and proper administration of our business. Essentially, this means that we process your data only as necessary to deliver the Service and for internal administration purposes, and in a manner that you understand and expect. We also carry out processing that is necessary to provide our Service to you under our t2bot.io Homeserver Terms and Conditions and processing that is necessary to comply with our legal obligations. Where consent is required by law in relation to certain processing, we will ask for your consent.

We process your information for the purposes of providing our decentralised, openly-federated and end-to-end encrypted communication Service, getting in touch with you, responding to your requests, working with our suppliers to deliver the Service and enabling its features, ensuring the security of our Service, developing, fixing and improving our Service, administering our business and complying with the law.

The nature of the Service and its implementation results in some caveats concerning this processing, particularly in terms of GDPR Article 17 Right to Erasure (Right to be Forgotten). We believe these caveats (discussed in the section below in detail) are in line with the broader societal interests served by providing the Service. In situations where the interests of the individual appear to be in conflict with the broader societal interests, we will seek to reconcile those differences guided by our policy.

Your rights as Data Subject

You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. Some of these rights are explored in more detail elsewhere in this document. For completeness, your rights under GDPR are:

The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling

We may ask for proof of identity before responding to your request. For more details about these rights, please see the guidance provided by the ICO. If you have any questions or are unsure how to exercise your rights, please contact us using the contact methods in the first section of this document.

Please note that we consult with The Matrix.org Foundation C.I.C. on how to process some requests. We commit to excluding your identifying information from the consultation process whenever possible, though may be required to provide a verbatim copy of your request to The Foundation for processing. You will be informed prior to these actions taking place.

t2bot.io offers a service where your account on another third party service may be represented through us. Your rights extend to the t2bot.io representation of your third party account, pending verification that you are the account owner/operator on that third party service. For the purposes of this document, representational accounts are referred to as "your account".

Right to erasure

You can request that we forget your copy of messages and files by instructing us to deactivate your account and indicating to us that you want us to forget your messages. What happens next depends on who else had access to the messages and files you had shared.

Any messages or files that were only accessible by your account will be deleted from our servers within 30 days.

Where you shared messages or files with another registered Matrix user, that user will still have access to their copy of those messages or files. Apart from state events (see 'Exceptional erasure' below), these messages and files will not be shared with any unregistered or new users who view the room after we have processed your request to be forgotten.

State events are processed differently to non-state events. State events are used by the Service to record, amongst other things, your membership in a room, the configuration of room settings, your changing of another user's power level and your banning a user from a room. Were we to erase these state events from a room entirely, it would be very damaging to other users' experience of the room, causing banned users to become unbanned, revoking legitimate administrator privileges, etc. We therefore share state events sent by your account with all non-essential data removed ('redacted'), even after we have processed your request to be forgotten. This means that your username will continue to be publicly associated with rooms in which you have participated, even after we have processed your request to be forgotten. We are monitoring The Matrix.org Foundation's work to solve this restriction and allow you to be fully forgotten while maintaining a high quality experience for other users. If this is not acceptable to you, please do not use the Service.

Because an account deactivation actions the removal of any data which could be used to validate the ownership of an account, it is our policy to not reactivate deactivated accounts. This measure is in place to protect the privacy and integrity of all accounts.

Exceptional erasure

As described above, erasing a state event may result in our needing to erase the entire conversation at the same time. Deciding whether to take this drastic step will require a balancing exercise to be carried out at the time of the request, and will depend on:

the nature of the Personal Data that the user is requesting to be erased;
how many other users would have their fundamental rights and freedoms put at risk if the Right to Erasure were to be exercised
to what degree these other users would have their fundamental rights and freedoms put at risk if the Right to Erasure were to be exercised

The Personal Data contained in a state event is usually limited to the username, the timestamp and the conversation in which the state event was issued. State events only represent that a user participated in a given conversation at a given time. It is rare that this data is sensitive enough to warrant its erasure given the drastic impact this will have on other users.

Each case will be decided based on the factors listed above. In most situations we will not erase state events. In extreme situations, where not erasing state events will place people at material risk of harm, we may choose to erase state events or remove the entire conversation.

Data portability

Under GDPR you have a right to request a copy of your data in a commonly-accepted format. If you would like a copy of your data, please send a request to the contacts listed in the first section of this document.

What Information Do You Collect About Me and Why?

The information we collect is purely for the purpose of providing your communication service via Matrix. We do not profile users or their data on the Service.

Be aware that while we do not profile users on the Service, third party Matrix clients may gather usage data. Similarly, third party services we represent your messages on may gather usage data.

Information you provide to us

We collect information about you when you input it into the Service or otherwise provide it directly to us.

Account and profile information

We collect information about you when representing you. This information is kept to a minimum on purpose, and is restricted to the following.

Username (if the third party service offers one)
Display Name (if you have one set)
Avatar (if you have one set)
Third party service identifiers (account/user IDs, etc). These identifiers may be internal and not fully visible to you on either service.

Content you provide through using the Service

We store and distribute the messages and files you share using the Service (and across the wider Matrix ecosystem via federation) as described by the Matrix protocol and according to the access rules configured within the system. Storing and sharing this content is the reason the Service exists.

This content may be processed by third party services when using a t2bot.io bridge or protocol converter.

This content includes any information about yourself that you choose to share.

Information we collect automatically as you use the Service

Currently, we log the IP addresses and user agents of everyone who accesses the Service. This data is used in order to mitigate abuse, debug operational issues, and monitor traffic patterns. Our logs are kept for not longer than 180 days.

What information is shared with third-parties and why?

We may share your information when working with our suppliers in order to provide the Service.

In addition, the t2bot.io homeserver is a decentralised and open service. This means that, to support communication between users on different homeservers or different messaging platforms, your username, display name, avatar, and messages and files are sometimes shared with other services that are connected with the t2bot.io homeserver.

Federation

Matrix homeservers share user data with the wider ecosystem over federation.

When you send messages or files in a room, a copy of the data is sent to all participants in the room, including (depending on room settings) participants who join the room in future. If these participants are on remote homeservers, your username, display name, avatar, messages and files may be replicated across each participating homeserver.

We will forget your copy of your data upon your request. We will also forward your request to be forgotten onto federated homeservers. However - these homeservers are outside our span of control, so we cannot guarantee they will forget your data.

Federated homeservers can be located anywhere in the world, and are subject to local laws and regulations.

Access control settings are shared between homeservers, as well as any requests to remove messages by "redactions", or remove personal data under GDPR Article 17 Right to Erasure (Right to be Forgotten). Federated homeservers and Matrix clients which respect the Matrix protocol are expected to honour these controls and redaction/erasure requests, but other federated homeservers are outside of the span of control of t2bot.io, and we cannot guarantee how this data will be processed. Federated homeservers can also be located in any territory, and will be subject to the local regulations of that territory.

Bridging and Protocol Conversion

Protocol conversion is a form of bridging which does not re-encrypt messages, if re-encryption would otherwise be required to operate the bridge.

Some Matrix rooms are bridged to third-party services, such as Discord, Telegram, or the physical postal network. When a room has been bridged, your username, display name, avatar, messages and file transfers may be duplicated on the bridged service where supported.

It may not be technically possible to support your management of your data once it has been copied onto a bridged service. Bridged services can be located anywhere in the world, and are subject to local laws and regulations.

Access control settings, requests to remove messages by "redactions" or remove personal data under GDPR Article 17 Right to Erasure (Right to be Forgotten) are shared to bridging services, which are expected to honour them to the best of their ability. Be aware that not all bridged networks or bridges support the necessary technical capabilities to limit, remove or erase messages. If this is not acceptable to you, please do not use bridged rooms, which includes the majority of t2bot.io's Service.

Integration services (bots and widgets)

The t2bot.io homeserver provides a range of integrations in the form of Widgets (miniature web applications accessed as part of a Matrix Client) and Bots (automated participants in rooms).

Bots and Widgets currently have access to all the messages and files in any room in which they participate, although The Matrix.org Foundation C.I.C. is adding a more sophisticated access control system. We are monitoring that work.

Transfers of your data

If you use our Service your data will be transferred outside of the EU to other homeservers and services connected with t2bot.io as this is necessary to provide the Service to you. By the very nature of our Service, such transfers will occur regularly and we have no control over the safeguards adopted by third party recipients.

Where we engage suppliers to process your data outside the EU we will ensure that appropriate safeguards such as the Standard Contractual Clauses are in place.

In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to:

comply with any applicable law, regulation, legal process or governmental request,
protect the security or integrity of our products and services (e.g. for a security audit),
protect t2bot.io and our users from harm or illegal activities, or
respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the serious bodily harm of any person.

We typically provide this information through The Matrix.org Foundation C.I.C. for the purposes of involving law enforcement. The Foundation's guidelines can be found here.

t2bot.io will abide by The Foundation's guidelines when sharing data with law enforcement directly.

How do you handle passwords?

t2bot.io does not process passwords or sensitive account credentials (access tokens, etc). t2bot.io does not have access to your account and only relies on details which are publicly visible or provided directly to the Service.

Our commitment to children's privacy

We never knowingly collect or maintain information in the Service from those we know are under 16, and no part of the Service is structured to attract anyone under 16. If you are under 16, please do not use the Service.

How can I access or correct my information?

You can request a download of a copy of all your data as per section 2.1.3.

Who can see my messages and files?

In unencrypted and encrypted rooms, users connecting to the t2bot.io homeserver (directly or over federation) will be able to see messages and files according to the access permissions configuration of the relevant room. This data is stored in the format it was received on our servers, and can be viewed by our developers and engineers (employees, contractors, and owners) under the conditions outlined below.

Rooms have different visibility settings which are determined by the room administrators. The history visibility possibilities are the following, by increasing order of openness (least open first):

joined: people need to join the room to see the history, and will only see the messages sent after they joined.
invited: people can only see messages sent after they were joined, no history is visible before that point.
shared: people need to join the room to see the history, but will then see the history up to when this visibility setting was set (the change is not retroactive).
world_readable: everyone can see the room history without even joining the room.

If you share information in a room set to world_readable this might be available to people outside the Matrix ecosystem and indexed by search engines, via projects such as archive.matrix.org. Please ensure that you double check the settings of each room before you participate and always avoid sharing personal and sensitive data in unencrypted rooms.

In encrypted rooms, the data is stored in our databases but the encryption keys are stored only on your devices or by yourself. We are unable to read your message content in our database. If you lose access to your encryption keys, you lose access to your messages forever.

We use HTTPS to transfer all data. End-to-end encrypted messaging data is stored encrypted using AES-256, using message keys generated using the Olm and Megolm cryptographic ratchets.

What are the guidelines t2bot.io follows when accessing my data?

We restrict who can access user data to roles which require access in order to maintain the health of the Service.

We have technical procedures in place to prevent unauthorised access to user data.

We never share what we see with other users or the general public.

Who else has access to my data?

We host the majority of the Service in Hetzner data centres. Hetzner's privacy policy is available here. We have a signed Data Processing Agreement with Hetzner to allow data to transit their networks.

We additionally host parts of the Service in DigitalOcean data centres. DigitalOcean's privacy policy is available here.

Physical access to our offices and locations use typical physical access restrictions.

We use secure private keys when accessing servers via SSH, and protect our passwords locally with a password management tool. We also use and require 2FA where available.

We log application data (username, user IP, and user agent). We keep logs for no longer than 180 days.

What happens if t2bot.io is sold?

In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

If we or substantially all of our assets are acquired by a third party, personal data held by us about our users will be one of the transferred assets.

How is my data protected from another user's data?

All of our users' data for the Service currently resides in the same database cluster which is due to the nature of our Service. We use software best practices to guarantee that only people who you designate as viewers of your data can access it. In other words, we segment our user data via software. We do our best and are very confident we're doing a good job at it, but, like every other service that hosts their user data on the same database, we cannot guarantee that it is immune to a sophisticated attack.

What should I do if I find a security vulnerability in the Service?

Please refer to our Security Disclosure Policy for information on how to report a security issue with the Service.

Please act in good faith towards our users' privacy and data during your disclosure. White hat security researchers are always appreciated.

Making a Complaint

We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention using the contact methods in the first section of this document if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

If you want to make a complaint about the way we have processed your personal information, please contact your local supervisory authority for reporting details.

Document history

v1.0 - first version - November 2020
v1.1 - update to align with matrix.org - May 2024

A note to other startups: this document was heavily inspired by Balsamiq's plain English ToS document. We were impressed by their championing of plain English, and wanted to reproduce that as much as possible in our own legal documentation. Feel free to draw similar inspiration from this document, though be sure to get any documents you produce checked over by a lawyer. Good luck!

This document is heavily inspired by matrix.org's privacy notice.