Effective: October 10, 2025
Europe Privacy Policy
Introduction
This section supplements Anuvyx’s main Privacy Policy for individuals located in the European Economic Area (EEA), the United Kingdom, or Switzerland (collectively, “Europe”). If you are outside Europe, the main Privacy Policy applies to you and this section does not. If you are in Europe, read this document together with the main Privacy Policy for region-specific information.
1. Data controller
Anuvyx S.A.S., incorporated in Colombia, is the data controller for your personal data unless we state otherwise. For our contact details, see Section 9 of the main Privacy Policy.
2. Legal Bases
Our purposes, the data we use, and the legal bases
Provide and operate the Service (including generating output from your input)
- Data we use: Account Data, Communication Data, User Content, Technical/Usage Data, and—if you choose to link social accounts—public social posts (e.g., public X posts) and related sign-in data (for 18+ users).
- Legal basis: Performance of a contract with you. Where no contract applies, our legitimate interests in delivering and maintaining the Service (including personalizing responses and interactions you request).
Process payments
- Data we use: Account Data, Communication Data, Payment Data.
- Legal basis: Performance of a contract (to take payment). If no contract applies, legitimate interests in processing a payment you request.
Provide support and customer assistance
- Data we use: Account Data, Communication Data, User Content (as needed to troubleshoot), Technical/Usage Data, Feedback Data.
- Legal basis: Performance of a contract. Otherwise, legitimate interests in operating, improving, and communicating about the Service.
Develop and improve the Service
- Data we use: Communication Data, User Content, Feedback Data, Technical/Usage Data.
- Legal basis: Legitimate interests in analyzing, improving, and developing the Service and user experience.
Train and enhance our models
- Data we use: Publicly available data, User Content, Feedback Data, and (for 18+ users who opt to link X) public X posts.
- Legal basis: Legitimate interests in improving the accuracy, safety, and performance of the models that power the Service and in building more advanced models.
Keep the Service secure and ensure integrity
- Data we use: Account Data, Communication Data, User Content (as relevant to investigations), Feedback Data, Technical/Usage Data.
- Legal basis: Legitimate interests in detecting, preventing, and responding to illegal activity, policy violations, and security incidents; protecting our IT infrastructure and the safety of users, employees, and vendors.
Communicate with you (service messages and, where allowed, marketing)
- Data we use: Account Data, Communication Data, Social Data (if you interact via social platforms), Other Information You Provide, Technical/Usage Data (including Log/Device data), Cookies and similar technologies.
- Legal basis: Performance of a contract for essential service communications (e.g., feature or security notices). For marketing or other non-essential messages, your consent where required; otherwise legitimate interests in keeping you informed about our Services and events.
Comply with laws and protect rights, privacy, safety, and property (Arex, users, or third parties)
- Data we use: Account Data, User Content, Communication/Social Data, Data from other sources (e.g., security partners), Technical/Usage Data (including Log/Device), Cookies and similar technologies, and Payment/transaction records as required.
- Legal basis: Compliance with legal obligations (e.g., age assurance in Europe, record-keeping, responding to lawful requests). Where no specific obligation applies, legitimate interests in preventing misuse, pursuing legal remedies, limiting damages, and safeguarding people and property.
Operate and grow our business (analytics and commercial activities)
- Data we use: Account Data, Communication Data, Social Data, User Content, Feedback Data, Technical/Usage Data (including Log/Device/Usage), Cookies and similar technologies, and data we receive from other sources.
- Legal basis: Legitimate interests in analytics, understanding usage trends, identifying prospective customers, developing new products, and expanding our business operations.
Sensitive data
We do not seek to collect sensitive personal information (e.g., racial or ethnic origin; political opinions; religious or philosophical beliefs; health; biometric or genetic data; criminal history; trade-union membership). Please do not provide such information.
When we rely on legitimate interests
Where we process data on the basis of legitimate interests (ours or a third party’s), we perform a documented balancing test to weigh those interests against potential impacts on you and to confirm the interests are not overridden by your rights and freedoms. You can request more information about this assessment using the contact details at the end of this notice.
3. Data Transfers
Anuvyx may process and store your personal data outside the European Economic Area (EEA), Switzerland, & the United Kingdom, including on servers located in Colombia and in other jurisdictions where our service providers operate. Regardless of where processing occurs, we apply the safeguards described in this Privacy Policy to your personal data.
Transfer mechanisms.
When we transfer personal data from the EEA, Switzerland, or the UK to countries that may not provide the same level of data protection, we use one or more of the following safeguards:
- Adequacy decisions. We rely on decisions by the European Commission, UK authorities, or Swiss authorities that recognize a destination country as providing an adequate level of protection when such decisions apply.
- Standard contractual protections. For other destinations, we use the European Commission standard contractual clauses and, where relevant, the UK International Data Transfer Addendum or equivalent UK and Swiss approved terms.
- Data Privacy Framework participation. For transfers to participating United States entities, we may rely on the EU to U.S. Data Privacy Framework, the UK extension to that framework, or the Swiss to U.S. Data Privacy Framework, as applicable.
Service providers.
We engage carefully vetted vendors that may access or process personal data on our behalf. These vendors are bound by written agreements that require appropriate security, confidentiality, and, where relevant, protections for any onward transfers consistent with the mechanisms described above.
Your rights.
You may contact us to request more information about our transfer safeguards or, where permitted by law, to obtain a copy of the relevant contractual terms.
4. Your rights
What you can ask us to do
You may, subject to applicable law, request that we:
- Access the Personal Data we hold about you and details of how we process it.
- Correct inaccurate or outdated Personal Data.
- Delete your Personal Data.
- Limit (restrict) how we process your Personal Data.
- Transfer your Personal Data to you or a third party in a portable format (data portability).
- Object to processing based on legitimate interests, and object to direct marketing (including related profiling) at any time.
- Withdraw consent where we rely on consent; this does not affect processing carried out before withdrawal.
- Lodge a complaint with your local data protection or supervisory authority.
How to exercise your rights
If you have an Anuvyx account, some requests can be made directly in your account settings (including, where available, opting out of using your information to help train our models). If you cannot complete a request in your account—or if you do not have an account—contact us at support@anuvyx.com.
We may ask for information to verify your identity before acting on a request.
About model-generated output (Arex)
Services like Arex generate text by predicting likely next words from a prompt. This means the output may not always be factually accurate. Please do not rely on model output for factual accuracy.
If Arex output includes factually inaccurate information about you and you want it corrected or removed, email support@anuvyx.com. We will consider your request in line with applicable law and the technical limits of our models; in some cases, a correction or removal may not be technically feasible.
Marketing preferences
You can opt out of our marketing communications at any time. We may still send non-promotional messages (for example, about your Arex access, legally required notices, or ongoing service updates).
Jurisdiction-specific notes
- France: You may direct us to retain or delete your Personal Data after your death, or to disclose it to a designated third party or recipient.
Exceptions
We may deny or limit a request where an exception applies (for example, if we need to retain data to comply with legal obligations or to establish, exercise, or defend legal claims). If an exception applies, we will tell you.
Contact
Questions or requests regarding your rights: support@anuvyx.com. For additional contact details, see Section 9 of our main Privacy Policy.