This document is the English-language version of the privacy policy. In the event of any inconsistency between the English-language version and the Dutch-language version, the Dutch-language version shall prevail.
Arkintel B.V. is a company registered in the Netherlands, with the following information:
This privacy policy describes how personal data is collected, used, and protected in connection with the DelftGPT AI chat platform (the "Services").
Arkintel is committed to protecting the privacy of users of the DelftGPT platform. We process personal data lawfully and carefully.
DelftGPT is an AI chat assistant for employees of Gemeente Delft. It is currently in a field trial and development phase.
Chat storage and AI processing take place on servers in the Gemeente Delft datacenter, on hardware owned by the Municipality. Some supporting services remain external, such as sign-in, secure traffic routing, frontend delivery, and privacy-friendly analytics.
This privacy policy should be read in conjunction with our Terms of Service, which govern your use of the Services.
For the purposes of the GDPR:
If you have questions about your data or want to exercise your rights, you can contact Arkintel at the privacy contact email address listed at the top of this document, or contact the privacy officer of Gemeente Delft.
Gemeente Delft has a Functionaris Gegevensbescherming (FG) as required under the GDPR. For questions about how the Municipality processes your data through DelftGPT, you may contact the FG of Gemeente Delft.
Arkintel B.V. has not appointed a separate Data Protection Officer.
DelftGPT does process normal account and usage data needed to run the service, such as your sign-in details, chat history, feedback, and technical logs. However, the platform is not intended for uploading personal case data, sensitive data, or other protected information into chat prompts or uploaded files.
If actual usage patterns show that DelftGPT is being used to process personal or sensitive content in practice, the DPIA determination will be revisited.
When you log in to DelftGPT, the following information is received from the Municipality's Microsoft Entra ID system:
| Data field | Purpose |
|---|---|
| Display name | Personalisation of the interface |
| Email address | User identification and account linking |
| Entra ID user identifier | Unique account identification |
This information is provided by the Municipality's identity system. Arkintel does not independently collect or verify this data.
| Data field | Purpose |
|---|---|
| Chat messages (your input and AI responses) | Core chat functionality and chat history |
| Uploaded files (content processed by the AI) | Document analysis and chat context |
| Chat history | Allowing you to review and continue previous conversations |
| Feedback (upvotes, downvotes, suggestions) | Quality measurement and system improvement |
| Model selection preferences | User experience personalisation |
When you access the Services, the following technical information may be collected:
This information is collected for the purposes of platform security, error detection, and performance monitoring.
Personal data is processed on the following legal bases (Article 6 GDPR):
| Processing activity | Legal basis | GDPR Article |
|---|---|---|
| User authentication via Entra ID | Legitimate interest | 6(1)(f) |
| AI chat functionality and chat history | Legitimate interest | 6(1)(f) |
| Feedback and benchmark evaluation during Phase 2 | Legitimate interest | 6(1)(f) |
| Privacy-friendly web analytics | Legitimate interest | 6(1)(f) |
| Platform security and error logging | Legitimate interest | 6(1)(f) |
The main legitimate interest is the Municipality's interest in providing employees with a secure AI productivity tool and improving it during the current field trial.
In assessing this interest, the following points are relevant:
We use the information we process for the following purposes:
We do not use your data for:
Chat history is stored so you can review and continue earlier conversations.
Each user can only access their own chats in the platform.
In specific audit cases or when the Gemeente is required to do so, the Gemeente may request export of a user's chat data.
Chat content, uploaded files, chat history, and AI processing are handled on servers in the Gemeente Delft datacenter, on hardware owned by the Municipality.
Some supporting services remain external. For example:
Arkintel and the Municipality apply appropriate technical and organisational measures to protect data against unauthorised access, alteration, disclosure, or destruction. These measures include:
While we take strong measures to protect your data, no system can promise zero risk.
Backups are stored on the Municipality's Petabyte storage cluster and replicated to a secondary location managed by the Municipality.
The following sub-processors are involved in the delivery of the Services:
| Sub-processor | Purpose | Data processed | Location |
|---|---|---|---|
| Cloudflare Inc. | Secure traffic routing and security | User IP address and request metadata needed to deliver traffic securely | Global edge network |
| Vercel Inc. | Frontend delivery and privacy-friendly web analytics | Static frontend assets, request metadata in transit, and anonymous aggregated page view data | Global edge network |
| Microsoft (Entra ID) | Authentication and access control (SSO) | User identity tokens | Microsoft cloud (configured by the Municipality) |
No AI processing is performed by external sub-processors. All AI models run on-premises on the Municipality's servers. No chat content, uploaded files, or user data is sent to external AI providers.
Arkintel reserves the right to engage additional sub-processors in the future. Where a new sub-processor is engaged that materially affects the processing of personal data, this privacy policy will be updated accordingly.
The platform uses third parties only where needed to deliver sign-in, secure traffic routing, frontend delivery, and analytics as described in this policy.
Gemeente Delft, as data controller, may have access through authorized administrators for compliance, audit, or operational reasons.
Aggregated or sufficiently anonymised usage information may be used for quality measurement and reporting.
The DelftGPT platform uses strictly necessary cookies required for the technical operation of the service:
We do not use:
Because the platform uses only strictly necessary cookies, no cookie consent banner is required for those cookies.
DelftGPT uses Vercel Web Analytics, a privacy-friendly, cookieless analytics service. It provides aggregated usage information, such as page views and visitor counts, to help improve the service.
Vercel Web Analytics does not place cookies on your device.
| Data category | Retention period |
|---|---|
| Chat history and user data | Retained according to the retention rules agreed between Arkintel and Gemeente Delft. |
| Uploaded files | Processed as part of the chat session and chat context. |
| Technical and security logs | Recorded in anonymised form |
| Feedback data | Retained according to the retention rules agreed for quality measurement and service evaluation |
When a user's access is revoked by the Municipality, the user can no longer access the platform. Retention and deletion after that point follow the agreed municipal retention setup.
Primary chat storage and AI processing take place on-premises in the Gemeente Delft datacenter in the Netherlands.
Some supporting services may involve international processing of limited technical or authentication data, depending on how those services deliver their network and cloud infrastructure.
No chat content, uploaded files, or AI processing data is sent to external AI providers.
Under the GDPR, you have the following rights:
To exercise any of these rights, please contact Arkintel at the privacy contact email address listed at the top of this document, or contact the privacy officer of Gemeente Delft.
We will respond to your request within one (1) month of receipt. This period may be extended by a further two (2) months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month, together with the reasons for the delay.
Verification of your identity may be required before a request is processed.
You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes the GDPR. The competent supervisory authority in the Netherlands is:
Autoriteit Persoonsgegevens Postbus 93374, 2509 AJ Den Haag Website: https://autoriteitpersoonsgegevens.nl
We encourage you to contact us first so that we can try to resolve your concern directly.
In the event of a personal data breach, Arkintel will notify Gemeente Delft without undue delay. Gemeente Delft, as data controller, will handle any required notifications to the Autoriteit Persoonsgegevens and to affected users.
Arkintel keeps this privacy policy under review and will place updates on this page. The "Version" and "date" fields at the top of this document show the current version and effective date.
Material changes will be communicated through the platform or through the Municipality's internal channels.
The Services may contain links to other websites or services. Arkintel is not responsible for the privacy practices or content of those external services.
This privacy policy is governed by the laws of the Netherlands and the GDPR.