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GDPR Statement

Last updated: 20 September 2026

Our commitments to data subjects in the EEA, the UK, and Switzerland.

Draft — not legal advice. This document is a working draft and must be reviewed by qualified counsel before it is relied upon.

Phronesis AI Lab Private Limited ("we", "us", "our") is committed to protecting the personal data of individuals in the European Economic Area, the United Kingdom, and Switzerland in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection. This statement supplements our Privacy Policy.

1. Roles: controller and processor

We are the controller for personal data relating to our account holders and website visitors. We are a processor for the customer content and connected-account data that customers instruct us to process, governed by our Data Processing Addendum.

2. Lawful bases for processing

  • Contract: to provide the Service you request.
  • Legitimate interests: to secure, maintain, and improve the Service, balanced against your rights.
  • Consent: for optional analytics and marketing, withdrawable at any time.
  • Legal obligation: to comply with applicable law.

3. Your rights as a data subject

  • Right of access to your personal data.
  • Right to rectification of inaccurate data.
  • Right to erasure ("right to be forgotten").
  • Right to restriction of processing.
  • Right to data portability.
  • Right to object to processing based on legitimate interests or for direct marketing.
  • Right not to be subject to solely automated decisions with legal or similarly significant effects.
  • Right to withdraw consent at any time.

Exercise your rights by emailing [email protected]. We respond within one month, extendable where permitted.

4. International data transfers

As we and our subprocessors operate globally (see the list in our Privacy Policy and Trust Center), personal data may be transferred outside the EEA and the UK. We rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, and supplementary measures to safeguard such transfers.

5. Automated processing and AI

The Service uses AI models to generate content at your direction. This is not automated decision-making that produces legal effects on data subjects. You control whether generated content is published. See our AI Content Terms.

6. Data retention and security

We retain personal data only as long as necessary for the purposes described in our Privacy Policy and apply the safeguards described on our Security page.

7. Supervisory authority and complaints

You have the right to lodge a complaint with your local Data Protection Authority. In the UK, this is the Information Commissioner's Office (ICO). We ask that you contact us first at [email protected] so we can try to resolve your concern.

8. EU/UK representative

Where required under Article 27 GDPR, we will appoint and identify a representative in the EU and/or the UK. Contact [email protected] for current details.

9. Contact

Privacy team: [email protected].

Last updated: 20 September 2026.