Privacy Policy

Last updated: 11th June 2025

1. Introduction

Williams Initiatives Ltd., operating as WhatProblem ("we," "us," or "our"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your information when you use our GitHub application.

2. Information We Collect

2.1 Information from GitHub

When you install WhatProblem, we receive:

• Your GitHub username and organization name
• GitHub Installation ID and Account ID
• Repository names where the app is installed
• Issue content and metadata for issues where the bot is invoked
• Issue comments and conversation history
• Basic profile information publicly available on GitHub

2.2 Usage Information

We automatically collect:

• Number of clarification requests made
• Monthly and daily usage breakdown
• Response times and interaction patterns
• AI model usage (tokens consumed)
• Error logs and performance metrics
• Subscription plan and trial status

3. How We Use Your Information

We use the collected information to:

• Provide the WhatProblem service
• Post clarifying questions and summaries as comments on GitHub issues
• Improve our clarification algorithms
• Monitor usage for beta program limits
• Debug issues and improve performance
• Communicate service updates (through GitHub)

3.1 Legal Basis for Processing

Under UK GDPR, we process your personal data based on:

• Legitimate Interests: We have a legitimate interest in providing and improving our service, ensuring security, and preventing abuse. We have conducted a legitimate interests assessment and determined that our interests do not override your rights and freedoms.
• Contract Performance: Processing is necessary for the performance of our Terms of Service contract with you.
• Legal Compliance: We may process data to comply with legal obligations.

4. Data Storage and Security

Your data is:

• Encrypted in transit and at rest
• Stored on Google Cloud Platform infrastructure in the US (us-central1 region)
• Persisted in Google Cloud Firestore
• Accessed only by authorized personnel
• Conversation history retained for service continuity
• Usage data archived monthly for billing purposes

5. Data Sharing

We do not sell, trade, or rent your personal information. We may share data only:

• With AI service providers (Anthropic Claude and OpenAI) for processing clarification requests
• With Google Cloud Platform for infrastructure services
• To comply with legal obligations
• To protect our rights and safety
• With your explicit consent

6. AI Processing

WhatProblem uses artificial intelligence to process issue content. By using our service, you acknowledge that:

• Issue content will be processed by third-party AI models (Anthropic Claude and OpenAI)
• We do not use your data to train public AI models
• AI responses are generated in real-time
• Full conversation history is stored for context continuity
• Extracted requirements are stored separately for reference

7. Data Retention

We retain your data for different periods depending on the type:

• Conversation history: Retained while you have an active installation plus 30 days after uninstallation
• Usage data: Archived monthly and retained for 24 months for billing, compliance, and service improvement purposes
• Account information: Retained until you uninstall the application plus 30 days
• Error logs: Retained for 90 days for debugging and service improvement
• Billing records: Retained for 7 years as required by UK tax law

Upon uninstallation, we will delete your personal data within 30 days, except where longer retention is required by law or for legitimate business purposes as outlined above.

8. International Data Transfers

Your personal data may be transferred to and processed in countries outside the UK, including:

• United States: Where our infrastructure (Google Cloud Platform) and AI service providers (Anthropic and OpenAI) are located

We ensure appropriate safeguards are in place for international transfers through:

• Standard contractual clauses approved by the UK Information Commissioner's Office
• Ensuring our service providers maintain appropriate security measures
• Only transferring data to organizations with adequate data protection measures

9. Your Rights

Under UK GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we use your data
• Objection: Object to our processing of your data
• Portability: Receive your data in a structured, commonly used format
• Withdraw consent: Where processing is based on consent

To exercise any of these rights, please contact us using the details in the Contact section. We will respond to your request within one month.

10. GitHub Integration

Our service operates as a GitHub App. GitHub's own privacy policy applies to data within GitHub's platform. We only access data that you explicitly authorize through the GitHub App installation.

Important: When you use WhatProblem:

• The AI will post comments on GitHub issues in your repositories
• These comments will be visible to anyone who can view the issue
• Comments include clarifying questions and requirement summaries
• All comments are clearly labeled as coming from WhatProblem bot
• You can delete any bot comments through GitHub's interface

11. Children's Privacy

WhatProblem is not intended for use by individuals under the age of 13. We do not knowingly collect personal information from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated revision date.

13. Contact Us

For privacy-related questions or to exercise your rights, please contact us:

• Email: [email protected]
• Postal Address: Williams Initiatives Ltd, 182-184 High Street North, Office 7556, London, United Kingdom, E6 2JA

When contacting us about your data rights, please provide sufficient information to identify you (e.g., your GitHub username and organization name).

14. Data Protection Officer

As a UK company, we take data protection seriously. For formal data protection inquiries, contact our Data Protection Officer through the channels above.

15. Complaints

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Phone: 0303 123 1113
• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us first.

16. Website Analytics

We use Google Analytics to understand how visitors use our website. This helps us improve our service and website experience. Google Analytics collects:

• Pages visited and time spent on each page
• General location (country/city level)
• Browser and device type
• How you arrived at our website

We have configured Google Analytics to:

• Anonymize IP addresses
• Disable advertising features
• Disable data sharing with Google

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

WhatProblem is a trading name of Williams Initiatives Ltd.
UK Company Number: 14929985.