Last updated: July 23, 2026
The Daml Coding Assistant hosted service, including its autocompletion API and VS Code extension (the “Service”), is operated by IntellectEU NV (“IntellectEU”, “we”, “us” or “our”).
This Privacy Notice explains how we process Personal Data when you register for or use the Service. It supplements the IntellectEU General Privacy Policy. If there is any conflict concerning the processing described here, this Privacy Notice applies.
The contractual terms governing the use of code and other content submitted through the Service are set out in the Daml Coding Assistant Terms of Use.
The Controller responsible for the processing described in this Privacy Notice is:
IntellectEU NV
Kanaalbrugstraat 15-5.1
1500 Halle
Belgium
Privacy questions and requests may be sent to: privacy@intellecteu.com
When you register for or access the Service, we may process:
If you register using an e-mail address and password, we retain your e-mail address and a password hash. If you use Google Sign-In, we retain only your e-mail address and permanent technical Google account identifier; the name, profile picture, locale and e-mail-verification status received during sign-in are not retained.
When the extension submits a completion request, the Service may process:
This information is processed to authenticate the request, generate the requested completion, operate and secure the Service, troubleshoot technical issues and apply usage limits.
When optional code sharing is disabled, code content and file paths are not retained after the completion request has been processed. The access token is also used only to authenticate the request and is not retained in the Service logs.
Only Daml files are read. The full edited file may be transmitted without a separate size cap, although only approximately 7,000 tokens nearest the cursor are used to generate the completion. File paths are workspace-relative, or a bare filename where no project folder is open, and are never absolute.
We may retain operational and security information such as:
Connection metadata, including IP addresses, may also be retained at the infrastructure layer. Where this information remains linked to an account, machine, IP address or organization, it is treated as Personal Data.
The Service allows users to make a separate, optional choice to share the Daml file content transmitted with a request, the generated completion, the workspace-relative file path and related acceptance feedback for model improvement, as described in the Terms of Use.
To the extent that such Shared Content contains or is linked to Personal Data, we process that Personal Data for the model-improvement purposes described in the Terms of Use.
The optional sharing setting is disabled by default. Refusing or disabling it does not prevent ordinary use of the Service.
Users may change their choice at any time through the
daml-coding-assistant.shareCodeSnippets setting.
Shared Content is associated with your Keycloak account identifier so that we can administer your choice and respond to privacy requests. Shared Content is not automatically filtered for Personal Data or credentials before it is stored or used for model improvement. Users should not enable sharing for content containing Personal Data relating to other individuals, credentials, highly sensitive information or information they are not authorized to disclose.
We process account, authentication and completion-request data to:
The legal basis is the performance of the agreement governing use of the Service.
Where a user accesses the Service on behalf of an organization, the legal basis may also include our legitimate interests and those of the organization in providing and administering the Service.
We process technical logs, IP addresses, machine identifiers and authentication activity to:
The legal basis is our legitimate interest in operating a secure and reliable service.
We process operational metrics to monitor performance, understand usage and improve the technical operation of the Service.
Where the information remains Personal Data, the legal basis is our legitimate interest in evaluating and improving the Service.
Where a user enables optional Shared Content sharing, the legal basis for processing Personal Data relating to that user within or associated with the Shared Content is consent.
The contractual and intellectual-property rights applicable to the underlying code or other content are governed exclusively by the Terms of Use.
We may process Personal Data where necessary to comply with applicable law, respond to lawful requests or establish, exercise or defend legal claims.
We retain Personal Data only for as long as necessary for the purposes described in this Privacy Notice.
The applicable retention periods are:
We may retain limited information for longer where required by law or necessary for legal claims.
A user may disable optional Shared Content sharing at any time through the extension setting or by contacting privacy@intellecteu.com.
Withdrawal:
Withdrawal does not require IntellectEU to delete or reverse models, model parameters, embeddings, statistical information or other resulting materials created before withdrawal, but only to the extent those materials no longer contain Personal Data relating to the user and do not reasonably allow such Personal Data to be reconstructed, extracted or linked back to the user.
Where resulting materials continue to contain Personal Data or allow it to be linked to an identifiable person, they remain subject to applicable data protection law.
Personal Data may be accessed by authorized IntellectEU personnel, contractors and Affiliates who require access to operate, secure, support or improve the Service and who are subject to appropriate confidentiality and data-protection obligations.
The Service is hosted using Google Cloud Platform. Google processes Personal Data on behalf of IntellectEU under the Google Cloud Data Processing Addendum and acts as a Processor for the relevant cloud-hosting services. The Addendum is incorporated into IntellectEU’s Google Cloud agreement and requires Google to process Personal Data on documented instructions, apply contractual security measures and assist with applicable deletion and data-subject obligations.
Google may engage authorized subprocessors in accordance with its Data Processing Addendum.
We do not sell Personal Data or disclose it to third parties for their independent marketing, advertising or model-training purposes.
Personal Data may nevertheless be processed:
If you choose Google Sign-In, Google processes the sign-in interaction under its own applicable terms and provides the account information described above to IntellectEU. Microsoft operates the VS Code Marketplace and may process installation and update telemetry relating to the extension under Microsoft’s own terms; Microsoft does not receive code, file paths or Service logs from IntellectEU for this purpose.
The main Service, model and log storage are hosted in Google Cloud us-east1
(South Carolina, United States). Keycloak account and authentication data are hosted
separately in Amazon Web Services eu-central-1 (Frankfurt, Germany). There
are no cross-region backups or disaster-recovery copies for the Google Cloud environment.
Google Cloud storage buckets use a 7-day in-region soft-delete period.
The transfer of Personal Data to the Google Cloud environment in the United States is governed by the applicable European Commission Standard Contractual Clauses incorporated into the Google Cloud Data Processing Addendum, unless another valid transfer mechanism applies. Amazon Web Services processes Keycloak account data in the European Economic Area under the AWS Data Processing Addendum; its applicable Standard Contractual Clauses apply to any restricted transfer made in connection with those services.
IntellectEU acts as Controller for the processing described in this Privacy Notice. Google Cloud and Amazon Web Services act as Processors for the hosting services they provide on IntellectEU’s behalf.
Further information about applicable international-transfer safeguards may be requested from privacy@intellecteu.com.
Most Personal Data is collected directly from the user or generated automatically through use of the Service.
Where Google Sign-In is used, the standard OpenID Connect profile information described in Section 3 is received from Google at the user’s request, but only the e-mail address and permanent technical account identifier are retained by IntellectEU.
Where an organization registers, approves or manages an account, we may receive the user’s professional contact details, organization and account-authorization information from that organization.
Account, authentication and completion-request information is necessary to create an account, authenticate requests and provide code completions. Without this information, the relevant Service functionality cannot be provided.
Sharing code and associated Personal Data for model improvement is optional. Refusing or withdrawing this choice does not prevent ordinary use of the Service.
The Service uses automated systems to generate code-completion suggestions.
These suggestions do not constitute decisions about the user and do not produce legal or similarly significant effects concerning the user.
We do not use Personal Data processed under this Privacy Notice to make decisions based solely on automated processing within the meaning of Article 22 GDPR.
Subject to applicable law, users may have the right to:
Requests may be submitted to privacy@intellecteu.com. We do not currently provide an automated data-export tool, but can identify and provide the relevant Personal Data manually in response to a valid request.
The supervisory authority responsible for IntellectEU NV is the Belgian Data Protection Authority. Users may also contact the supervisory authority in the country where they live or work or where they believe an infringement occurred.
We apply technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure and unauthorized access.
The extension reads only Daml files; however, Daml files may still contain Personal Data or confidential information, and Shared Content is not automatically filtered before storage or model improvement. Users should not submit credentials, highly sensitive Personal Data, production customer records or Personal Data relating to other individuals through the Service or optional Shared Content feature.
We may update this Privacy Notice to reflect changes to the Service, our processing activities or applicable law.
The updated version will be published at the same location and the “Last updated” date will be revised.
Where a change materially affects the processing of Personal Data or a previously provided choice, we will provide additional notice and request a new consent where required by applicable law.