GDPR and live chat: what your team decides, and what GreetDock does.
Live chat collects personal data from the first message: a name, an email address, the page someone is reading, sometimes their voice on a call. The GDPR sets rules for the business that runs the chat. This page explains them topic by topic, with what GreetDock does and the section of our legal documents that says so. This page is general information, not legal advice.
Is there such a thing as GDPR compliant live chat? Not as a product label.
The GDPR applies to processing, and Article 5(1)(a) says data must be "processed lawfully, fairly and in a transparent manner". That duty sits with the controller, and on your website the controller is your business. The chat vendor is your processor.
Article 28(1) says a controller "shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures". So ask two things of any vendor. Does it give you guarantees you can check? And does it make your own obligations easier to meet?
“No other certification, audit, insurance, uptime, or SLA claim is made for GreetDock or MB Helmar.”DPA Annex 2
What GreetDock does, topic by topic. Each row links to the section that says so.
- RolesArt. 4(7), 4(8), 28
You are controller, MB Helmar is processor. For agencies, MB Helmar is a sub-processor
Privacy Policy 2.2DPA 2.1DPA 2.4 - Lawful basis and visitor choiceArt. 6(1), 4(11), 7(3)
Calls and co-browsing start only on explicit acceptance. The visitor can end anything at any moment
Privacy Policy 7DPA 6.3 - TransparencyArt. 12, 13
Lists what your notice must say and provides a model-wording annex
DPA 4.2DPA 4.7 - Cookies and storageePrivacy Art. 5(3)
localStorage, no advertising identifiers. The current build writes an identifier at page load, so your consent tool must cover it
Cookie Notice 2Cookie Notice 4.1Cookie Notice 4.2DPA 4.7 - Analytics on your siteePrivacy Art. 5(3)
The widget never loads analytics
DPA 4.8Cookie Notice 4 - Processor contractArt. 28(3)
Published DPA, documented instructions, no training on your data
DPA 5.1DPA 5.4 - Sub-processorsArt. 28(2), 28(4)
Register on request, 21 days' notice (urgent replacements notified without undue delay), 14 days to object, obligations passed down
DPA 7.1 to 7.4 - Hosting and transfersArt. 44 to 46
Hosted in the EEA, self-hosted media relay, AI in Azure West Europe from 4 November 2026, SCCs required for any non-EEA processing
DPA 13.1DPA 13.3DPA Annex 1 FDPA 15.3 - SecurityArt. 32
Measures summarised in DPA Annex 2. ISO/IEC 27001:2022 certificate held by the hosting provider
DPA 6.1DPA Annex 2Privacy Policy 10 - BreachArt. 33, 34
Notice without undue delay, aiming for 48 hours
DPA 10.1 to 10.3 - RetentionArt. 5(1)(e), 13(2)(a)
You control it. Fixed periods: MCP log 90 days, accept-event log 3 years
DPA 2.2(d)DPA 4.6DPA 12.2DPA Annex 1 E - Data subject requestsArt. 12(3), 15 to 22
Forwarded within 3 working days, plus deletion and export help
DPA 9.1DPA 9.2DPA 12.2Privacy Policy 8.4 - RecordingsArt. 6, 13; national law
Never automatic, state always shown, visitor notice. "Ask first" mode from 4 November 2026
DPA 4.6DPA 15.3Privacy Policy 7 - AI featuresArt. 22, 28
From 4 November 2026: drafts only, a person sends every reply, processed in the EEA, no training
Privacy Policy 7DPA 4.9DPA 15.3DPA Annex 1 F - Co-browsingArt. 5(1)(c), 25
Shared view and pointer, no remote control, sensitive inputs hidden
DPA 6.3Privacy Policy 7
| GDPR topic | Law | What GreetDock does | Where it says so |
|---|---|---|---|
| Roles | Art. 4(7), 4(8), 28 | You are controller, MB Helmar is processor. For agencies, MB Helmar is a sub-processor | Privacy Policy 2.2DPA 2.1DPA 2.4 |
| Lawful basis and visitor choice | Art. 6(1), 4(11), 7(3) | Calls and co-browsing start only on explicit acceptance. The visitor can end anything at any moment | Privacy Policy 7DPA 6.3 |
| Transparency | Art. 12, 13 | Lists what your notice must say and provides a model-wording annex | DPA 4.2DPA 4.7 |
| Cookies and storage | ePrivacy Art. 5(3) | localStorage, no advertising identifiers. The current build writes an identifier at page load, so your consent tool must cover it | Cookie Notice 2Cookie Notice 4.1Cookie Notice 4.2DPA 4.7 |
| Analytics on your site | ePrivacy Art. 5(3) | The widget never loads analytics | DPA 4.8Cookie Notice 4 |
| Processor contract | Art. 28(3) | Published DPA, documented instructions, no training on your data | DPA 5.1DPA 5.4 |
| Sub-processors | Art. 28(2), 28(4) | Register on request, 21 days' notice (urgent replacements notified without undue delay), 14 days to object, obligations passed down | DPA 7.1 to 7.4 |
| Hosting and transfers | Art. 44 to 46 | Hosted in the EEA, self-hosted media relay, AI in Azure West Europe from 4 November 2026, SCCs required for any non-EEA processing | DPA 13.1DPA 13.3DPA Annex 1 FDPA 15.3 |
| Security | Art. 32 | Measures summarised in DPA Annex 2. ISO/IEC 27001:2022 certificate held by the hosting provider | DPA 6.1DPA Annex 2Privacy Policy 10 |
| Breach | Art. 33, 34 | Notice without undue delay, aiming for 48 hours | DPA 10.1 to 10.3 |
| Retention | Art. 5(1)(e), 13(2)(a) | You control it. Fixed periods: MCP log 90 days, accept-event log 3 years | DPA 2.2(d)DPA 4.6DPA 12.2DPA Annex 1 E |
| Data subject requests | Art. 12(3), 15 to 22 | Forwarded within 3 working days, plus deletion and export help | DPA 9.1DPA 9.2DPA 12.2Privacy Policy 8.4 |
| Recordings | Art. 6, 13; national law | Never automatic, state always shown, visitor notice. "Ask first" mode from 4 November 2026 | DPA 4.6DPA 15.3Privacy Policy 7 |
| AI features | Art. 22, 28 | From 4 November 2026: drafts only, a person sends every reply, processed in the EEA, no training | Privacy Policy 7DPA 4.9DPA 15.3DPA Annex 1 F |
| Co-browsing | Art. 5(1)(c), 25 | Shared view and pointer, no remote control, sensitive inputs hidden | DPA 6.3Privacy Policy 7 |
References are to the versions updated on 15 October 2026. Changes in that update, including the agency terms, the named AI sub-processor and the “ask first” mode, take effect on 4 November 2026.
Who is the controller, and who is the processor? The test is who decides why and how.
The EDPB's Guidelines 07/2020 on the concepts of controller and processor set out the test. Whoever decides why and how personal data is processed is the controller. Whoever processes it on the controller's behalf is a processor.
On your website, you are the controller. MB Helmar, the company behind GreetDock, is your processor.
Privacy Policy 2.2DPA 2.1If you are an agency running the widget on a client's site, your client is usually the controller, you are its processor, and MB Helmar is a sub-processor.
DPA 2.4Privacy Policy 2.2One record is ours, not yours. When a visitor accepts a chat, a call or co-browsing, MB Helmar logs that accept event as its own controller record.
DPA 2.2(d)Privacy Policy 3, row 8That log relies on legitimate interest and is kept for 3 years from each event. You see the consent status, not the log itself.
DPA 2.2(d)Privacy Policy 7
Lawful basis for chat, calls and co-browsing. Choosing it is your decision as controller.
Article 6(1) lists the lawful bases. Three come up for live chat: (a) consent; (b) contract, including steps taken "at the request of the data subject prior to entering into a contract"; and (f) legitimate interests.
Where you rely on consent, Article 4(11) sets the bar: "freely given, specific, informed and unambiguous". Article 7(3) adds that withdrawing consent must be as easy as giving it. The EDPB's Guidelines 05/2020 on consent explain how authorities apply this.
Having a valid legal basis for the data processed through GreetDock on your website is your responsibility.
DPA 4.1A conversation begins when the visitor engages. A greeting from your team may appear while a teammate is available, and the visitor can ignore or dismiss it.
Privacy Policy 7DPA 6.3A voice or video call, and any co-browsing session, starts only when the visitor explicitly accepts it in the browser.
Privacy Policy 7DPA 6.3The visitor can end any conversation, call or co-browse at any moment.
Privacy Policy 7Cookie Notice 4.3DPA 6.3The visitor needs no download, no meeting link and no account.
Privacy Policy 7
Tell visitors before you collect. Your privacy notice has to cover GreetDock.
Article 13 asks the controller to give certain information "at the time when personal data are obtained": the purposes and legal basis, the recipients, any transfer outside the EU, the retention period and the visitor's rights. Article 12(1) asks for it in a "concise, transparent, intelligible and easily accessible form, using clear and plain language".
The DPA lists what your notice must say about GreetDock. The next items are the ones teams most often leave out.
DPA 4.2From page load, GreetDock holds a short-lived server-side session for every visitor on a page with the widget: presence, current page and session metadata. It ends with the visit.
DPA 4.2DPA Annex 1, category 1Privacy Policy 7When a chat starts, its ticket holds session context, including an approximate location (city and country) from the IP address. The raw IP address is stored on the ticket too.
DPA Annex 1, categories 2 and 3Privacy Policy 7Your team can add profile details and internal notes to a visitor's ticket, and your notice must say how visitors can access them.
DPA 4.2MB Helmar provides a model-wording annex: a privacy-notice paragraph, a consent-banner line and guidance on loading the widget conditionally. It is a template, not legal advice, and is available at onboarding or from [email protected].
DPA 4.7
Cookies, local storage and the widget. Device storage has its own rules.
Article 5(3) of the ePrivacy Directive (2002/58/EC) needs consent for storing or reading information on a device. The exemption covers storage "strictly necessary in order for the provider of an information society service explicitly requested by the subscriber or user to provide the service".
The EDPB's Guidelines 2/2023 treat local storage like cookies once the information leaves the device. The ICO lists web storage as a storage technology, and the CNIL says refusing must be as simple as accepting.
The widget keeps its state in localStorage, not cookies.
Cookie Notice 2In the current build, the widget writes a persistent identifier to the visitor's device at page load.
Cookie Notice 4.1DPA 4.7Until that changes, your consent tool must cover the GreetDock identifier before the widget loads, and your cookie notice must disclose it.
DPA 4.7Cookie Notice 4.1PlannedAfter a committed change, the keys greetdock-visitor, greetdock-conversation and greetdock-prefs are created only at the visitor's first real interaction.
Cookie Notice 4.2DPA 4.7The widget sets no advertising or cross-site tracking identifiers.
Cookie Notice 4.2The GreetDock script loads only the widget. It never loads, configures or manages analytics on your site.
DPA 4.8Cookie Notice 4
Processors, sub-processors and the DPA. Article 28 asks for a contract, and ours is published.
Article 28(3) requires a contract between controller and processor. It covers the subject matter, duration, nature and purpose of the processing, the types of data and the people concerned. The processor must act "only on documented instructions from the controller". Under Article 28(2), a processor needs written authorisation before engaging another processor.
The DPA is published at /legal/dpa and forms part of our agreement with you.
DPA openingMB Helmar processes Customer Data only on your documented instructions.
DPA 5.1We do not use your data for our own purposes, sell it, or use it to train any model.
DPA 5.4You give a general authorisation for sub-processors. The current Subprocessor Register is available on request at [email protected] and is not published at a public URL.
DPA 7.1Each sub-processor takes on, by contract, data protection obligations giving in substance the same level of protection as the DPA.
DPA 7.4We notify you of a personal data breach without undue delay, aiming for 48 hours after we become aware.
DPA 10.1Audits start with documents: the DPA, our security overview, the register, the hosting provider's attestations, and answers to a security questionnaire (at most once per 12 months).
DPA 11.2
Data residency and transfers. The GDPR controls transfers, not location.
The GDPR does not require data to stay in the EU. Article 44 allows a transfer outside it only under the conditions of Chapter V. One route is a European Commission adequacy decision, under which data can flow "without any further safeguard being necessary". The UK is covered by one. In the US, only organisations taking part in the EU-US Data Privacy Framework are.
The service is hosted on infrastructure inside the EEA, and Customer Data is processed in the EEA.
DPA 13.1The real-time media relay (TURN/SFU) for voice, video and co-browse traffic is self-hosted by MB Helmar on the same hosting infrastructure. It is not a separate sub-processor.
DPA 13.1DPA Annex 1 FPrivacy Policy 4From 4 November 2026AI processing is done by Microsoft Ireland Operations Limited (Azure OpenAI Service) in the Azure West Europe region, in the Netherlands.
DPA Annex 1 FPrivacy Policy 5DPA 15.3If a sub-processor ever processes data outside the EEA without an adequacy decision, the DPA requires the 2021 Standard Contractual Clauses (Module Three) or another valid mechanism first.
DPA 13.3The hosting services and data centres are covered by ISO/IEC 27001:2022 certification. The certificate belongs to the hosting provider, not to MB Helmar or GreetDock.
DPA Annex 2Privacy Policy 10
How long chat data is kept. You set retention for your own records.
Article 5(1)(e) says data must be kept "for no longer than is necessary for the purposes". Article 13(2)(a) asks you to tell visitors the retention period, or the criteria used to set it. The ICO's guidance on storage limitation recommends standard retention periods and regular reviews.
Visitor tickets, conversations, recordings and workspace files are kept until you delete them or the workspace closes.
DPA Annex 1 EDPA 4.6Call transcripts and AI summaries follow your retention and are deleted with the record they belong to.
DPA Annex 1 EThe MCP request log is kept for 90 days. The AI provider may keep inputs for up to 30 days for abuse monitoring, and does not use them for training.
DPA Annex 1 EPrivacy Policy 7When the service ends, you choose return or deletion within 14 days, and it is completed no later than 30 days after the end.
DPA 12.2The accept-event log, which MB Helmar controls, is kept for 3 years from each event, also after your workspace closes.
DPA 2.2(d)DPA 12.1
When a visitor asks for their data. You answer, and we help.
Under Article 12(3), you must act on a request "without undue delay and in any event within one month of receipt", with two more months for complex or numerous requests. For the UK, the ICO notes that a person "can make a SAR by any means", so a request typed into your chat counts.
Requests about your website go to you as controller. If one reaches us, we forward it within 3 working days at the latest and do not answer it on the merits.
DPA 9.1Privacy Policy 8.4We help you access, correct, delete, export or restrict records.
DPA 9.2During the beta there is no self-serve deletion tool. You email [email protected], and we carry out the deletion without undue delay.
DPA 9.2On return at the end of the service, structured records come as JSON, and media and files in their original formats.
DPA 12.2Requests about the accept-event log are answered by MB Helmar itself, because it is our own record.
DPA 9.1Privacy Policy 8.4
Call recordings, transcripts and AI summaries. A recording is a new record.
The law of several member states requires every participant's consent before a call is recorded, as our DPA notes. In France, the CNIL says each caller must be told at the start of the call about the purpose, the recipients, their right to object and their right of access.
Recording is never automatic. A member of your team starts it, and the call screen always shows the state, with "Media is not recorded" when it is off.
Privacy Policy 7Cookie Notice 4.3The visitor sees a recording indicator and notice when recording starts.
DPA 4.6The DPA says the indicator and notice "are notice, not consent". Where consent is required, you must get it before recording, or not record.
DPA 4.6Transcripts and AI summaries are created only from calls your team records.
Privacy Policy 7From 4 November 2026The AI drafts replies, and a person on your team reviews and sends every one. The AI never answers visitors on its own.
Privacy Policy 7DPA 4.9DPA 15.3
Co-browsing and hidden fields. What your team can see matters more than any banner.
Article 5(1)(c) asks that data be "limited to what is necessary", and Article 25 asks for data protection by design and by default. For co-browsing, both come down to what the session lets your team see.
Co-browsing is a shared view of the page with a pointer, spotlight and pen.
Privacy Policy 7DPA Annex 1, category 8Your team can never control the visitor's browser.
Privacy Policy 7DPA 6.3Sensitive inputs are hidden from the team view.
DPA 6.3A session starts only when the visitor accepts it, and the visitor can stop it at any moment.
DPA 6.3
What stays your job. GreetDock can make the steps visible. It cannot make your decisions.
- 01
Choose and document your lawful basis.
DPA 4.1 - 02
Disclose GreetDock in your privacy and cookie notices.
DPA 4.2DPA 4.7 - 03
Cover the current widget identifier in your consent tool before the widget loads.
DPA 4.7 - 04
Decide whether to record, and make sure recording is lawful where you operate.
DPA 4.6 - 05
Set and apply retention for your records.
DPA Annex 1 E - 06
Answer visitor requests about your website.
DPA 9.1 - 07
Keep special-category data out of the service, which is not designed for it.
DPA 4.3 - What GreetDock does not do
GreetDock does not certify your compliance, choose your lawful basis, run your consent banner or answer visitor requests for you. It has no remote control, and during the beta it has no self-serve deletion tool.
Questions data protection teams ask about live chat.
Is GreetDock GDPR compliant?
No vendor can promise that for you, because compliance depends on how your business uses the tool. GreetDock acts as your processor under a published Article 28 DPA and is hosted in the EEA, and calls and co-browsing start only when the visitor accepts them. Your notice, lawful basis and retention stay your decisions. This is general information, not legal advice.
Where is chat data stored?
On hosting infrastructure inside the EEA. Voice, video and co-browse streams go through a media relay that MB Helmar self-hosts on the same infrastructure, and from 4 November 2026 AI processing runs in the Azure West Europe region, in the Netherlands (DPA, Section 13.1 and Annex 1, Section F).
Does the GreetDock widget need to sit behind our cookie banner?
In the current build, yes. The widget writes a persistent identifier at page load, so your consent tool must cover it before the widget loads (DPA, Section 4.7). A committed change will move that write to the visitor's first real interaction.
Who are your sub-processors?
Providers for application and data hosting and for email, both in the EEA, and, from 4 November 2026, Microsoft Ireland Operations Limited (Azure OpenAI Service) for the AI features. The current Subprocessor Register is available on request at [email protected] (DPA, Section 7.1 and Annex 1, Section F).
Do you record calls?
Only when a member of your team starts a recording, and the call screen always shows the state. The visitor sees a recording indicator and notice when it starts. From 4 November 2026, an "ask first" mode lets the widget ask the visitor before recording begins (DPA, Sections 4.6 and 15.3).
What happens if a visitor asks us to delete their chat?
You are the controller, so you answer them. During the beta, you email [email protected] with the record to delete, and we carry it out without undue delay (DPA, Section 9.2). If the visitor writes to us instead, we forward the request to you within 3 working days (DPA, Section 9.1).
Is our data used to train AI?
No. Neither MB Helmar nor the AI provider uses Customer Data to train models (DPA, Section 5.4 and Annex 2).
Which supervisory authority oversees GreetDock?
MB Helmar's supervisory authority is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, VDAI) in Lithuania (DPA, Section 17.3; Privacy Policy, Section 8.5).
Read the DPA before you install anything. Every GreetDock claim on this page links to the section that makes it.
Sources for the law summaries, checked on 16 October 2026
- Regulation (EU) 2016/679 (GDPR), Official Journal L 119, 4 May 2016
- EDPB Guidelines 07/2020 on the concepts of controller and processor in the GDPR, version 2.0, 7 July 2021
- EDPB Guidelines 05/2020 on consent under Regulation 2016/679, 4 May 2020
- EDPB Guidelines 2/2023 on the Technical Scope of Art. 5(3) of the ePrivacy Directive, version 2.0, 7 October 2024
- ICO: "What are storage and access technologies?", "Principle (e): Storage limitation" and "How do we recognise a subject access request (SAR)?"
- CNIL: "Cookies et traceurs : que dit la loi ?" (29 September 2020) and "Enregistrement ou écoute des conversations téléphoniques : faut-il informer ses clients/usagers ?"
- European Commission: "Adequacy decisions"
This page is general information, not legal advice. Your data protection officer or counsel decides what applies to your business.
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