PRIVACY POLICY
1. INTRODUCTORY PROVISIONS
1.1. The company VRGENS Limited, ID 126948, incorporated: 09.07.2024 with registered office at Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, 969 60 Marshall Islands, ("Controller", "Company" or "We") operates and provides access to the web-based AI Hub and Terminal services under licence from the respective product owner (the "Service"). Users acknowledge that when using the Service, they interact with an AI system, not a human.2. PROCESSING OF PERSONAL DATA
2.1. If you use the Service, the Company becomes the controller of your personal data within the meaning of Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("Regulation").3. CATEGORIES OF PERSONAL DATA
3.1. If you are using the Service, we might process the following categories of personal data:3.2. Wallet Data: your public wallet address, connected wallet provider, signature logs for authentication, and transaction records used for access verification and billing.
3.3. AI Inputs and Outputs: user prompts, uploaded files, configuration parameters, generated outputs, and moderation logs used for operation and safety of AI Agents.
3.4. Blockchain and Billing Data: wallet transactions for top-ups and subscriptions, transaction hashes, timestamps, and smart contract IDs used for recording and verifying payments.
3.5. Technical and Usage Data: IP address, browser type, device, OS, crash logs, and session timestamps collected for diagnostics and security.
3.6. Statistical data: demographic information, geographic, geo-location information, performance data and other statistical data.
3.7. Support and Communication Data: emails, messages, or bug reports sent to support channels or through the website.
3.8. Cookies: We use both session and persistent cookies to ensure functionality (essential cookies) and to gather analytics data (non-essential cookies), for which we may ask for your consent if required by law.
3.9. Other data: other information in your account that you provide us with.
3.10. We strongly discourage you from uploading any sensitive personal data (e.g., health information, biometric data, racial or ethnic origin, political opinions, religious or philosophical beliefs, etc.) to the Service, unless absolutely necessary for the intended purpose.
4. LEGAL TITLE AND PURPOSE OF PROCESSING
4.1. We process personal data for the following reasons:Processing of personal data based on applicable laws
4.2. We process your personal data based on applicable laws which apply to our business activities.
4.3. We may process limited logs of AI Inputs and Outputs for safety monitoring, incident reporting, and compliance with the EU AI Act. Such processing is strictly limited to what is necessary for audit and regulatory purposes.
Performance of contractual obligations
4.4. The Blockchain and Billing Data are processed to verify ownership of your connected Wallet, enable access to the Service, record and confirm payments made in VR tokens, and maintain an auditable transaction history for accounting and security purposes.
4.5. Wallet Data: your public wallet address, the connected wallet provider, and signature logs generated during the authentication process. These data are processed to verify that you control the connected Wallet, enable secure access to the Service, and record transactions necessary for access management, billing, and fraud prevention. The Company does not collect or store any private keys, seed phrases, or other credentials enabling access to your Wallet.
4.6. Technical data and technical cookies are processed to make the Service functional.
4.7. We process other data that you voluntarily provided to us to provide you with the respective services you requested (having more information in your account, support request etc.).
4.8. Inputs and Outputs may be temporarily stored on our servers for the purpose of providing the Service, improving its functionalities, and ensuring compliance with our Terms and conditions (e.g., to detect prohibited content). We may retain such Inputs and Outputs for a limited time, after which they are either anonymized or deleted unless otherwise required by law.
Processing of personal data based on legitimate interest
4.9. We process statistical data in order to prevent misuse of the Service, to ensure the functioning of the Service and improving the Service. The statistical data are processed in pseudonymised form, so that nobody except for us is able to match the data to the user. This processing is based on our legitimate interest, which is the continuous improvement of the Service.
4.10. Some of the statistical data can be used to prove cheating or another breach of Terms and conditions.
4.11. We might process your contact details to offer you similar goods or services to the Service. We can also send you information about news from our company, Christmas or birthday wishes and other information related to our brand and our products.
4.12. We may also analyze Inputs and Outputs to improve the AI model's accuracy and performance. This processing is based on our legitimate interest in continuously improving the Service. Where possible, we use anonymization or pseudonymization techniques to minimize the impact on your privacy.
Consent
4.13. We might ask you if you want us to process some of your data to use it for:
4.14. · marketing purposes: such as sending marketing communications, newsletters, or personalized offers (that do not fall within our legitimate interest).
4.15. · Cookies.
5. PROCESSORS, RECIPIENTS, AND TRANSFER OF PERSONAL DATA
5.1. For the effective operation of the Service and our company, we have contracts with other service providers to whom we may pass your personal data for processing. In particular, the following may process your personal data:5.2. Victoria VR Group, a.s., ID number 21924945, with its registered seat at Václavské náměstí 796/42, 110 00 Prague 1, Czech Republic, registered at Municipal Court in Prague, file number B 29030 established under the Czech law,
5.3. payment partners,
5.4. software and IT service providers (e.g. Google, Microsoft),
5.5. marketing service providers,
5.6. legal service providers.
5.7. We process your personal data exclusively in European Union countries. Outside of the European Union, we might process your personal data only if it is necessary for the performance of our contractual or legal obligations.
6. STORAGE TIME
6.1. We process personal data only for the time necessary to fulfil the purpose of processing or for the time required by law. The storage period varies depending on the legal title of the personal data processing:6.2. If the legal basis for the processing of personal data is the performance of contractual obligations, we process personal data for the duration of our contract and then 4 years after the contract is terminated or for period prescribed by or in accordance with applicable law.
6.3. If the legal basis for the processing of personal data is the fulfilment of our legal obligations, we process personal data for the period of time required by law.
6.4. If the legal basis for the processing of personal data is our legitimate interest, we process personal data for the duration of the legitimate interest, or until you notify us that you do not wish us to process the personal data further and then 4 years after the contract is terminated or for period prescribed by or in accordance with applicable law.
6.5. If your consent is the legal basis for the processing of your personal data, we will process your personal data for no longer than the duration of your consent.
6.6. Please note that some transaction records (e.g., blockchain payment hashes) are permanently stored on public ledgers and cannot be altered or deleted. Where erasure is technically impossible, the Company will ensure that such data are pseudonymised or de-linked from your account.
7. YOUR RIGHTS
7.1. In particular, you have the following rights in relation to your personal data:7.2. Right of access to personal data - you can contact us at any time to ask if we are processing your personal data and, if so, to request further information about this processing.
7.3. The right to correct or supplement personal data - if your personal data changes during the processing or if you feel that the data we process is incorrect, please contact us.
7.4. Right to request restriction of processing - in the cases referred to in Article 18 of the Regulation, you have the right to request restriction of the processing of your personal data.
7.5. Right to erasure of personal data - in the cases referred to in Article 17 of the Regulation, you have the right to request that we erase personal data concerning you without undue delay.
7.6. Right to request data transfer - under the conditions set out in Article 20 of the Regulation, you have the right to ask us to transfer your personal data to a third party.
7.7. Right to withdraw the consent to process your personal data. Where we process your personal data based on your consent You can withdraw such consent at any time by sending us a request at [email protected]
7.8. Right to object - where we process your personal data on the basis of our legitimate interest, you have the right to object to such processing at any time.
7.9. Right to lodge a complaint - if you have any doubts about our compliance with our obligations related to the processing of personal data, you have the right to lodge a complaint with the data protection regulator in your jurisdiction.
8. THE SOURCES OF YOUR PERSONAL DATA
8.1. We acquire your personal data from the following sources:8.2. Directly from you during your registration to Service, using Service or other of our services where necessary, by filling forms during your use of the Service or by direct communication with you.
8.3. From monitoring of the use of the Service.
9. CONTACT
9.1. If you want to contact us, make a complaint, ask us about anything related to the processing of your personal data or tell us that you do not want us to process your personal data, you can use the following contact details:9.2. E-mail: [email protected]
10. DATA SECURITY
10.1. In order to secure your data against unauthorized or accidental disclosure, we apply reasonable and appropriate technical and organizational measures, which are continuously updated. The technical measures consist of the deployment of technologies preventing unauthorised access to the data by third parties. Organizational measures are a set of rules of conduct of our coworkers and are part of our internal regulations, which are considered confidential for security reasons. If our servers are located in a data centre operated by a third party, we ensure that the technical and organisational measures are also implemented at this provider.11. PROCESSING OF PERSONAL DATA IN THE UNITED STATES
11.1. For users residing in the United States, the Company processes personal data in accordance with applicable U.S. privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Colorado Privacy Act (CPA), the Virginia Consumer Data Protection Act (VCDPA), the Connecticut Data Privacy Act (CTDPA), and the Utah Consumer Privacy Act (UCPA).11.2. We do not sell or share personal information for monetary consideration. We may disclose personal data to our service providers solely for operational business purposes described in this Privacy Policy.
11.3. U.S. users have the following rights under applicable state laws:
11.4. the right to know which categories of personal data we collect and how we use them;
11.5. the right to access and obtain a copy of your personal data;
11.6. the right to request deletion of your personal data, subject to applicable exceptions;
11.7. the right to correct inaccurate personal data;
11.8. the right to opt out of the sale or sharing of personal data, if applicable;
11.9. and the right to appeal a refusal to take action on a previous request.
11.10. To exercise these rights, you may contact us at [email protected]. We will verify your request according to applicable law and respond within the required statutory time frame.
11.11. We do not discriminate against users for exercising their privacy rights under U.S. law.
12. OTHER AND FINAL PROVISIONS
12.1. If you refuse to provide personal data necessary for the above purposes, we may not be able to provide you with our service.12.2. We process personal data via software, so the processing is at least partially automated.