Privacy and
Cookie Policy

01Important Distinction: Controller vs. Processor

Under European data protection law, our role depends on the type of data we process:

• Company as a Data Controller: We act as a Controller for personal data related to account management, billing, marketing, and usage analytics of our website and platform.
• Company as a Data Processor: When you upload data into the Service to be processed by our AI models (“Customer Data” or “Input”), you act as the Controller, and we act as the Processor. In these cases, the processing is strictly governed by our Data Processing Addendum (DPA).

02Categories of Data We Collect

We collect and process the following categories of personal data:

• Account & Identity Data: Name, business email address, company name, telephone number, and login credentials.
• Billing & Financial Data: Invoicing address, VAT number, and payment details (processed securely via a PCI-DSS compliant third-party payment provider).
• Technical & Usage Data: IP address, browser type, device identifiers, time-zone settings, and logs of your interactions with our platform or APIs.
• AI Input & Prompt Data: Any personal data that you voluntarily include within the prompts, text, files, or media you submit to our AI engines (“Input”).

03Legal Bases for Processing

In accordance with Article 6 of the GDPR, we rely on the following legal bases to process your data:

• Performance of a Contract: To create your account, provide access to the AI Service, process payments, and provide customer support.
• Legitimate Interests: To secure our platform, detect fraudulent usage, and optimize the technical performance of our infrastructure.
• Legal Obligation: To comply with fiscal, accounting, and regulatory obligations under Belgian law.
• Consent: Where you have explicitly opted-in to receive marketing communications or accepted non-essential cookies.

04AI Processing, Hybrid Infrastructure, and Model Training

Operating an AI platform in 2026 requires strict adherence to AI-specific privacy principles. Our platform utilizes a hybrid AI infrastructure:

• Sovereign European Hosting: Our platform, database, and open-source AI models are physically hosted in Belgium at Combell, a local Belgian data center, ensuring high-level local data sovereignty and security.
• Third-Party AI Infrastructure: To provide advanced capabilities, specific functionalities are routed via API to vetted third-party AI infrastructure providers, including OpenAI and Anthropic. All data sent through these APIs is processed strictly under data protection agreements that prohibit those third parties from using your data to train their models.
• No Training on Customer Prompts: We do not use personal data contained within your Inputs or Outputs to train, fine-tune, or optimize our proprietary or open-source machine learning models without your explicit, separate opt-in consent.
• Data Minimization: We strongly discourage users from submitting sensitive personal data (e.g., health data, political opinions, or biometric data) into the AI prompts. If such data is submitted, it is processed automatically and transiently.
• Automated Decision-Making: Our Service acts as a productivity tool. We do not use your personal data to perform automated individual decision-making that produces legal or significantly similar effects (Article 22 GDPR).

05Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy:

• Account Data: Retained for the duration of your active subscription and deleted 30 days post-termination.
• Billing Data: Retained for seven (7) years to comply with Belgian fiscal and accounting regulations.
• AI Cache/Logs: Transient Input logs used for system error detection are automatically deleted or thoroughly anonymized within thirty (30) days.

06Data Transfers Outside the EEA

While your primary account and metadata are securely hosted locally with Combell in Belgium, using third-party APIs (OpenAI / Anthropic) may involve data transit. Where data is transferred outside the European Economic Area (EEA), we ensure a valid transfer mechanism is in place, such as an EU Adequacy Decision or the execution of Standard Contractual Clauses (SCCs) combined with mandatory Transfer Impact Assessments (TIAs) to guarantee an equivalent level of protection.

07Your GDPR Rights

As a data subject under EU law, you possess the following rights, which you can exercise at any time by contacting [Insert Privacy Email]:

• Right of Access, Rectification, and Erasure ("Right to be Forgotten")
• Right to Restriction of Processing and Data Portability
• Right to Object: Object to processing based on legitimate interests or direct marketing.

01What Are Cookies?

Cookies are small text files that are stored on your computer or mobile device when you visit our website or platform. They help us make the website function properly, make it more secure, and analyze our traffic.

02How Do We Use Cookies?

We use cookies to distinguish between different types of platform interactions. We categorize cookies into three groups:

03Managing Your Cookie Preferences

When you first visit our platform, a cookie banner will prompt you to configure your choices.

• Consent: Non-essential cookies will only be activated after you click "Accept All" or customize your preferences to allow them.
• Withdrawal: You can change or completely withdraw your consent at any time by clicking the "Cookie Settings" link in our website footer or by clearing your browser cache.