QTS Agentic OS

Privacy notice for Agentic OS

Effective date: 20 October 2026, version 1.1

1. Controller and scope

The controller for account, billing, security and service-operation data is:

Bacalu Constantin-Iulian, trading as QTS One
Lehrter Str. 23A, 10557 Berlin, Germany
Email: contact@qts.one

This notice applies to agentic.qts.one, including sign-in, Account and Organisation administration, Contracts, Agents, Work Records, Sources, billing, support and security operations.

Where a customer uses Agentic OS to process personal data in its own repositories, messages, prompts or other connected Sources, that customer normally decides the purpose and means and is the controller. QTS One then acts as processor under an Art. 28 GDPR data processing agreement (DPA). This notice does not replace that DPA or the customer's own notice to its users and workers.

2. Data we process

Depending on use, Agentic OS processes:

  • identity data: email address, Clerk subject identifier (sub), optional display name, authentication and session data;
  • customer structure and access data: Account, Organisation, User Profile, Role Grant, Contract, Agent, Persona and Runner assignments;
  • work content and records: requests, connected Source identifiers, Work Records, Directives, prompts, model outputs, questions and answers, pull-request and repository metadata, Evidence Events and approval decisions;
  • billing data: Tier, billing contact email, Account and subscription state, Stripe customer/subscription/item identifiers, purchase and webhook events, invoice/customer-portal references, and optional VAT ID; QTS One does not store full card numbers;
  • telemetry and security data: timestamps, IP/network and request metadata where present in infrastructure logs, error and access logs, usage/token counts, provider/model route, cost telemetry, Runner heartbeats and incident evidence;
  • support data: sender address and the contents of messages sent to contact@qts.one;
  • withdrawal data: when you withdraw through the online withdrawal function on /withdrawal, your name, the contract identifier you enter, the email address for the receipt, the text of your withdrawal statement, the date and time we received it, and whether the receipt and our internal notice were delivered.

Do not put passwords, API keys, payment-card data, identity documents, health data or other special-category data into a Work Record unless a written customer agreement expressly allows it.

3. Purposes and legal bases

  • To create and operate the account, provide the selected Tier, route Work Records, run Agents and provide billing/customer-portal functions: Art. 6(1)(b) GDPR (contract or steps requested before contract).
  • To administer business-customer users where the individual is not the contracting party: Art. 6(1)(f) GDPR (our and the customer's legitimate interest in operating the contracted service).
  • To secure the service, prevent abuse, keep operational logs, investigate incidents and establish or defend legal claims: Art. 6(1)(f) GDPR.
  • To keep invoices, payment and tax records: Art. 6(1)(c) GDPR together with the applicable German commercial and tax retention duties, including § 147 AO and § 257 HGB.
  • To answer support and privacy requests: Art. 6(1)(b), (c) or (f) GDPR, depending on the request.
  • To receive, prove, confirm and handle a withdrawal declared through the online withdrawal function: Art. 6(1)(c) GDPR together with § 356a BGB; Art. 6(1)(f) GDPR only where the record is needed to establish, exercise or defend legal claims.
  • Where QTS One acts as processor for customer work content: the customer's documented instructions and Art. 28 GDPR govern the processing; the customer supplies the Art. 6 basis.

We do not use consent as a fallback for core service processing. If optional analytics or advertising technology is introduced, it needs a separate assessment and, where required, prior consent under § 25 TDDDG and Art. 6(1)(a) GDPR.

Waiting to join an Organisation

If you sign in to join an Organisation through a verified email domain and its Account has no free seat, we keep a waiting-join record while an Account Admin of that Account decides whether to admit you. The record contains only your User Profile ID, the Organisation, its Default Contract and the time you started waiting. Your name and email address are held in your User Profile; we do not copy them into the waiting-join record. We process your request to take steps you asked for before joining (Art. 6(1)(b) GDPR).

While the request is open, the Account Admins of that Account can see your name (if you provided one) and email address in the signed-in waiting list. The Account Admins receive one email about the request, without your name, email address or ID. We send this notification for the Organisation's legitimate interest in deciding who joins (Art. 6(1)(f) GDPR).

When an Account Admin admits or declines you, we delete the waiting-join record. If no Account Admin decides, we delete it after 30 days. Admission creates a Contract. Your separate User Profile follows the Account rules elsewhere in this notice.

4. Providers and recipients

  • Clerk provides sign-in and processes identity, session and device/network data.
  • Stripe / Sold through Link, LLC provides Checkout, Managed Payments, subscription billing, invoices, refunds and the customer portal. Stripe acts as merchant of record for eligible Managed Payments, but that payment role does not make Stripe the provider of Agentic OS.
  • Hetzner hosts the QTS One Kubernetes infrastructure and databases in Germany/Europe.
  • Grafana Cloud receives operational metrics and logs. Application secrets and Work Record content must not be intentionally logged.
  • Temporal infrastructure and the customer's Runner execute workflows and Directives. A Runner may hold a workspace and credentials selected by the customer.
  • LLM and CLI providers selected for the Runner, including OpenAI/Codex and Anthropic/Claude where configured, receive the Directive content needed to perform the requested work. The available provider depends on the Runtime Profile and Runner configuration.
  • Hetzner stores withdrawal records, and our email delivery provider sends the receipt to you and the notice to contact@qts.one.
  • Connected providers such as GitHub or Slack receive or supply data only when the customer configures the corresponding Source or integration.

We disclose data to authorities or advisers only where required by law or needed to establish, exercise or defend legal claims.

5. International transfers

Some providers may process data outside the European Economic Area, including in the United States. A transfer is permitted only with a Chapter V GDPR safeguard, such as an adequacy decision under Art. 45 GDPR (including an applicable EU–US Data Privacy Framework certification) or Standard Contractual Clauses under Art. 46 GDPR plus any necessary supplementary measures. The applicable mechanism depends on the contracted provider entity and current certification. Customers should select an EU region or EU provider where available and avoid unnecessary personal data in prompts.

6. Retention

  • Temporal workflow history follows the Organisation retention setting, currently configurable from 1 to 90 days.
  • Workspaces and Work Record data are retained for the period needed to provide the Contract and the configured Organisation retention, subject to technical deletion controls and legal holds.
  • User Profile rows, email addresses and Evidence Events may be retained after deactivation where needed to preserve the audit trail and defend claims.
  • Billing and tax records are retained for the statutory period under § 147 AO and § 257 HGB.
  • Security and operational logs are kept only for 14 days.
  • Support messages are kept only as long as needed to answer and document the request, subject to legal duties and claims.
  • Withdrawal records are kept until the end of the regular limitation period, normally three years from the end of the year in which the withdrawal was received (§§ 195 and 199(1) BGB), and then deleted, unless a dispute or legal hold requires us to keep them longer.

When no fixed period applies, we review necessity using purpose, contract status, security needs, limitation periods and legal holds. We delete or anonymise data when it is no longer needed.

7. Cookies and browser storage

Agentic OS uses Clerk and technically necessary browser storage or cookies for sign-in, session security and requested application functions. These are used under § 25(2) Nr. 2 TDDDG where strictly necessary. The current code does not declare optional advertising or analytics cookies. Optional tracking must not be added without updating this notice and implementing consent where required.

8. Your rights

Subject to the statutory conditions, you can request access (Art. 15 GDPR), correction (Art. 16), deletion (Art. 17), restriction (Art. 18), portability (Art. 20), or object to processing based on legitimate interests (Art. 21). You may complain to a data-protection supervisory authority (Art. 77). Contact: contact@qts.one. We may verify your identity before acting.

If QTS One processes the data only on a customer's behalf, we will refer the request to that customer or assist it under the DPA.

9. Automated decisions and AI

Agentic OS uses AI systems to carry out user-requested engineering work and may generate code, reviews, summaries or other outputs. Outputs can be wrong and may require human review under the customer's governance settings. QTS One does not make a decision producing legal or similarly significant effects about a person solely through this processing within Art. 22 GDPR on the facts currently verified.