Privacy Policy

1Introduction & scope

Auxerta is an artificial-intelligence research company. The Service permits a registered user (a “User,” “you,” or “your”) to publish dated posts, apply a mood, tags, and a limited set of typographic effects, and engage in social features including following, “keeps,” “notes,” and a “circle” of mutual connections, with each entry set to private, connections-only, or public visibility.

This Policy applies to personal information that we process about Users and visitors through the Service, including the Service website, the embeddable text-effect widget, and the optional typography “studio.” For the purposes of applicable data-protection laws, Auxerta acts as the controller (or business) with respect to the Personal Information described in this Policy. “Personal Information” means information that identifies, relates to, or could reasonably be linked with an identified or identifiable individual.

2Information we collect

We collect the following categories of information, including, without limitation:

(a) Account and profile information. Information that you provide when you register for and maintain an Account:

• your email address;
• a password, which is stored in hashed form and is not retained by us in plain text;
• a chosen handle and display name;
• your date of birth, collected at registration and used for age-related purposes only, namely enforcing the age requirement in Section 11, deciding whether strong language is shown uncovered or masked, and, where a report concerns a minor, forming part of a report to the National Center for Missing & Exploited Children (Section 6a). Your date of birth is not displayed and is not disclosed to any other User. A User may elect, in the Account settings, to publish the day and month of that date on their profile; the year is never published, displayed, or disclosed in any circumstance, whether or not that election is made, because the year discloses the User’s age. Where the election is made, Users within the electing User’s accepted circle are shown a notice on the corresponding day of each year, which states the electing User’s display name and does not state any date. The election is off by default and may be withdrawn at any time, with immediate effect;
• an optional biography (“bio”);
• an optional name by which the Assistant (Terms, Section 5A) addresses you. This name need not be your display name or your handle. It is shown only to you, is not displayed to any other User, is not published, and is used for no purpose other than addressing you in messages from the Assistant. It may be changed or cleared at any time in your Account settings, and clearing it causes the Assistant to fall back to your display name and then to your handle; and
• preferences that you may set, comprising a self-declared language and your chosen display colours.

(a-2) Account status and subscription records. Information generated by the operation of your Account rather than provided by you:

• whether your email address has been confirmed, and the time of confirmation. Until it is confirmed, entries are stored privately and the features described in the Terms are unavailable;
• where you subscribe, an identifier assigned by Stripe, Inc. to your customer record and the date through which your subscription is paid. Auxerta does not receive, transmit, or store your payment card number, which is handled by Stripe alone (Section 4);
• counts of the entries, replies and connection requests you have made in the current day, of the reviews you have written in the current week, and of the pictures you have posted in the current month, together with the day, week, or month each count belongs to. These exist to enforce the limits stated in the Terms, are reset when the corresponding period turns, are not disclosed to any other User, and are not used to decide what you are shown; and
• where staff have taken action in respect of your Account, the records described in Section 3(b).

(a-1) Country. Where a User has consented to usage recording (Section 3), Auxerta records the country from which that User signs in, for the purpose of understanding where the Service is read. The value is limited to a two-letter country code. It is obtained from the country determination supplied by the content-delivery network that fronts the Service, which computes it at the network edge; Auxerta does not transmit a User’s IP address to any geolocation provider for this or any other purpose. Auxerta does not record a User’s city, region, coordinates, or any location more precise than a country, and does not ask a User to declare a location. Where a User has not consented, or where no country determination is available, no country is recorded. Withdrawing consent erases the country records already held for that User, in addition to preventing further recording; the authentication records described in Section 3 are retained on a separate basis and are unaffected.

(b) Your Content. The text and other material that you create, publish, or otherwise submit through the Service (“Your Content”), together with associated metadata such as the mood, tags, typographic effects, and visibility setting that you apply to an entry. An entry may also be a review of a work.

(b-1) Photographs attached to an entry. The Service accepts a photograph attached to an entry. The Service does not accept User-submitted video.

Such a photograph is stored in the form in which it is submitted. Auxerta does not re-encode it and does not remove embedded metadata. Accordingly, any metadata it carries, including, without limitation, Exchangeable Image File Format (“EXIF”) data such as camera and device identifiers, timestamps, and geolocation coordinates, is stored together with that photograph and forms part of Your Content. Users who do not wish such metadata to be stored should remove it prior to submission.

(b-2) Works made in the studio. The studio composes a work from a User’s typed words, drawn marks, and outlines supplied by Auxerta within the Service. It is available to every signed-in User. The studio does not accept, import, or process a photograph, a video, or any other image file, and provides no facility to do so, so no image from a User’s device and no metadata such a file carries reaches Auxerta or is stored by it. What is submitted, and what Auxerta stores, is the work itself: a still image rendered from it on the device, an animation where the User has applied motion, and a snapshot of the underlying document.

The snapshot exists so that a User may re-open and edit their own work. It is served only to the User who created it, at any visibility setting, and is not carried in feeds or delivered to any other User. It remains available to Auxerta staff for the safety purposes described in Section 3 and to comply with legal obligations.

A work made in the studio is member-created imagery, and Section 3 describes the review that applies to it before it reaches anyone else. The words a User composes within a work are read by the same automated language screening applied to the text of an entry, and are read by a curator during that review. They are not otherwise used, and Section 5 excludes them, together with the images themselves, from AI Licensing in every case.

Image files are addressed by a non-sequential identifier derived from the file’s contents and are served independently of the entry in which they appear. Access to an image file associated with an entry that is not public is restricted to Users entitled to view that entry. Where an entry is public, the associated image file is likewise public and may be retrieved by any person holding its address, without authentication, including after that address has been forwarded to a third party.

(c) Technical and usage information. Collected automatically when you use the Service:

• Internet Protocol (IP) address. Auxerta records the IP address from which an Account is registered, the IP address associated with the most recent authentication, and, for each authentication session, an IP address, a browser identification string, and associated timestamps. Auxerta processes this information on the basis of its legitimate interest in the security and integrity of the Service, including the detection of unauthorised account access, evasion of enforcement action, and coordinated abuse, and in order to satisfy the reporting obligations described in Section 6a. This information is not disclosed to other Users.
• Reading activity. Where a User who has consented to usage recording under Section 3(a) opens an entry authored by another User, Auxerta records that access; where consent has not been given, or has been withdrawn, no such record is made or retained. The author of an entry is shown the aggregate number of Users who have accessed it and the number of such Users within the author’s circle; those figures accordingly count only consenting readers and understate total readership. The identity of an individual reader is not disclosed to the author or to any other User.
• Device-derived time information. Auxerta records the calendar date and Internet Assigned Numbers Authority time-zone identifier reported by a User’s device at the time of submission, so that an entry is filed under the date on which it was written. In the case of a restaurant review, Auxerta additionally records a two-character country code derived from the browser’s declared language setting.
• Visit measurement. For each page requested from the Service, including by a visitor who holds no Account, Auxerta records the page requested, the domain name (but not the full address) of any website that referred the request, any campaign parameters present in the address, and whether the request appeared to originate from automated software. Auxerta additionally derives a short identifier by combining the requesting IP address, the browser identification string, the current date, and a secret value; the IP address is used only for this derivation and is not stored. The identifier is pseudonymous. It groups the pages requested by one visitor within a single day, so that arrivals can be counted; because the current date forms part of the derivation, a new identifier is generated each day, and the identifier is of no use on any other website. This measurement sets no cookie and writes nothing to your device, and is accordingly not subject to the choices described in Section 7. Records of visit measurement are retained for thirty (30) days and are then deleted automatically. Auxerta processes this information on the basis of its legitimate interest in understanding how the Service is found and used.
• Log data reflecting requests made to the Service, processed to operate, maintain, secure, and improve the Service.

(c-1) Review prior to publication. Certain entries are withheld from publication pending human review. Such review is applied where an entry designated other than private carries a User-submitted image, and in the further circumstances set out in the Content Policy. While an entry is withheld, it is visible to its author alone. Authorised personnel of Auxerta review the entry, including any image it carries, for the purpose of releasing or refusing publication. Users should therefore be aware that a withheld entry may be read by personnel of Auxerta before it becomes visible to any other User.

(c-2) Private messages and calls. Private messaging and calling are available only to Users to whom Auxerta has granted access to those features; where you have not been granted access, no such information is created. Where you exchange private messages (“Ping”) with another User, Auxerta stores the text of those messages so that they may be delivered and shown to the two Users party to the conversation. Message content is not used for advertising, is never included in the de-identified corpus described in the Terms, and is not licensed to any third party. Auxerta does not read private messages in the ordinary course; a member of the two-person conversation may report a message, in which case Auxerta freezes and reviews a copy of the reported message and the surrounding messages for the purpose of enforcing the Terms. Message content is automatically and permanently deleted thirty (30) days after it is sent, and may be deleted sooner by a party to the conversation or upon erasure of an Account; a copy frozen for the review of a report (above) is retained only for so long as is necessary to resolve that report. Where you place or receive a voice call, Auxerta stores a record of the call — the Users party to it, the time it was placed, its duration, and how it ended — but does not record, store, or have access to the audio of the call, which travels directly between the two Users’ devices in encrypted form. Private messages you have written and your call records are included in the export described in Section 6 and are deleted when you erase your Account.

(d) Communications. Information that you provide when you contact us, including support requests, accessibility feedback, and other correspondence.

3How we use information

We use the information described above for the following purposes, including, without limitation:

• to create, authenticate, and secure your Account;
• to send you service communications to the email address on your Account, comprising a message confirming that address at registration, a message containing a single-use link by which a forgotten password may be reset, and such notices as this Policy or the Terms require us to give. Each such message is sent because it is necessary to operate your Account or to perform our agreement with you; none is marketing, and Auxerta does not send marketing email. A link contained in a confirmation or reset message expires and may be used once;
• to provide, operate, maintain, and improve the Service and its features;
• to enforce visibility settings and to deliver Your Content consistent with your selections;
• to respond to your communications and provide support;
• to maintain the safety and integrity of the Service, including detecting, preventing, and addressing fraud, abuse, security incidents, and violations of the Terms;
• to conduct manual, human review of entries that appear substantially AI-generated and to apply, and where appropriate remove, an AI label;
• to administer the optional paid subscription described in the Terms; and
• to comply with our legal obligations and to establish, exercise, or defend legal claims.

Usage recording and safety records

Auxerta maintains two categories of record concerning a User’s use of the Service. Each rests on a separate lawful basis, and only the first is subject to the User’s election.

(a) Usage recording (optional). Where a User has given consent, Auxerta records that User’s use of the Service, including the entries that User opens. Consent is requested separately at registration, is not pre-selected, and is not a condition of registration or of access to any feature. A User may give or withdraw consent at any time in the Account settings, and withdrawal is effected by the same single action as consent. Withdrawal takes effect immediately and both prevents further recording and erases the usage records already held about that User, comprising the record of the entries that User has opened and the country records described in Section 2(a-1). Erasure is carried out at the time of withdrawal and without further request. Where consent has not been given, or has been withdrawn, Auxerta does not record the entries that User opens. This processing is carried out on the basis of consent (GDPR Art. 6(1)(a)).

(b) Safety records (not optional). Independently of paragraph (a), Auxerta retains the records necessary to maintain the security and integrity of the Service and to comply with its legal obligations, comprising authentication records (including IP address, browser identification string, and associated timestamps), reports made by or concerning a User, warnings issued to a User, and enforcement action taken. These records permit the detection and investigation of abuse, impersonation, evasion of enforcement action, and unlawful material, and the making of reports required by law, including those described in Section 6a. They are not subject to election, and the withdrawal of consent under paragraph (a) does not affect them. This processing rests on Auxerta’s legitimate interests in the security and integrity of the Service and on compliance with legal obligations (GDPR Art. 6(1)(f) and 6(1)(c)).

(c) Limitations applicable to both categories. No record described in this Section is used to determine the promotional material shown to a User, and no such record is disclosed to an advertiser. Section 9 of the Terms provides that no information relating to a User determines the promotional material that User is shown, and that provision is unaffected by this Section. Authorised personnel of Auxerta may access the records of an individual Account where necessary to review a report or to enforce the Terms, and each such access is recorded in an internal audit log.

Auxerta does not sell your Personal Information. The Service is funded by Users and by advertising sold directly by Auxerta. Auxerta does not operate, and does not participate in, an advertising network; the Service employs no advertising auction, no behavioural or interest-based targeting, and no third-party advertising or tracking technology. Each advertisement is sold and selected by Auxerta and is presented identically to every User to whom the relevant page is served, and no information relating to a User determines what is shown. The image accompanying an advertisement is hosted by Auxerta rather than retrieved from the advertiser, such that requesting a page carrying an advertisement does not disclose a User’s IP address to that advertiser. Auxerta discloses no Personal Information to an advertiser and does not inform an advertiser of the identity of any User who views or selects an advertisement. Selecting an advertisement directs the User to a website operated by the advertiser and not by Auxerta; information collected on that website, including by the advertiser’s own analytics, is collected by the advertiser and is governed by that advertiser’s privacy policy and not by this Policy.

4Legal bases for processing

Where the General Data Protection Regulation (EU) 2016/679 or the United Kingdom GDPR (collectively, the “GDPR”) applies, we process Personal Information only where we have a lawful basis to do so. The legal bases on which we rely include, without limitation:

• Performance of a contract: to provide the Service to you in accordance with the Terms, including creating your Account and delivering Your Content according to your visibility settings;
• Legitimate interests: to operate, secure, and improve the Service, to prevent abuse and fraud, and to protect our rights and those of our Users, where such interests are not overridden by your interests or fundamental rights and freedoms;
• Consent: for AI Licensing as described in Section 5 and for any future processing for which consent is required; you may withdraw your consent at any time, prospectively, as described in Section 9; and
• Compliance with legal obligations: to comply with applicable law and lawful requests from public authorities.

5AI Licensing & de-identification

Because Auxerta is an artificial-intelligence research company, we state the following expressly. The licensing of Your Content for the development of artificial-intelligence models (“AI Licensing”) is strictly opt-in and consent-based.

• We do not use Your Content for AI Licensing unless you affirmatively consent. Absent your consent, Your Content is not used to develop, train, or improve AI models and is not disclosed for that purpose.
• If you affirmatively consent, Auxerta may use Your Content, and may license it to Auxerta and to third-party research partners and AI laboratories, to develop AI models. Before any such content leaves Auxerta, it is de-identified through the removal of your name, email address, handle, and other direct identifiers. AI Licensing helps fund the Service.
• Only entries you have designated public, created while your consent stands, are eligible. Entries designated private or friends-only, and any content connected to Auxerta’s support resources (including concern reports and crisis-support interactions), are never used or disclosed for AI Licensing.
• Consent establishes eligibility only: inclusion in any training corpus is by Auxerta’s curated selection, and not all eligible content is included. We will notify you through the Service no later than the first time Your Content is included in a corpus used to train models or delivered to a licensee.
• Your consent is revocable prospectively. Revocation halts the future use and disclosure of Your Content for AI Licensing but cannot recall content already disclosed or undo training already completed.
• An entry that Auxerta, upon human review, labels as involving artificial intelligence is excluded from AI Licensing.
• Auxerta does not sell your identity, contact details, or other Personal Information.

6How we share information

Auxerta does not sell your Personal Information. We disclose information only as described in this Policy, including, without limitation:

• Service providers. With vendors and service providers that perform services on Auxerta’s behalf, in each case under contractual obligations restricting their use of the information to the provision of those services. Such providers presently compriseAmazon Web Services, Inc. (hosting, database, storage, security, logging, and the transmission of the service communications described in Section 3, for which purpose a User’s email address and display name are disclosed to Amazon Simple Email Service, processed in the United States) and Stripe, Inc.(payment processing), to which Auxerta discloses a User’s email address and an internal account identifier. Auxerta does not receive or store payment card details;
• Catalogue lookups. Where a User employs the work-selection facility within the composer to identify a book, film, album, programme, or game that is the subject of a review, the search terms entered by that User are transmitted from Auxerta’s servers to Wikidata(Wikimedia Foundation, Inc.) and Open Library (Internet Archive) for the purpose of identifying the work. No identifier of the User is transmitted; the recipient receives the search terms and Auxerta’s server address only. Such transmission occurs at the time of entry, including in respect of a review subsequently designated private;
• Opt-in research partners and AI laboratories. As de-identified content, with research partners and AI laboratories, solely with respect to Users who have affirmatively consented to AI Licensing and solely after de-identification, as described in Section 5;
• Legal and safety. Where we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request, to enforce the Terms, or to protect the rights, property, or safety of Auxerta, our Users, or others, including reporting of apparent child sexual exploitation to the National Center for Missing & Exploited Children (“NCMEC”) as required by 18 U.S.C. § 2258A; and
• Business transfers. In connection with, or during negotiations of, any merger, acquisition, financing, reorganization, or sale of assets, or in the event of insolvency, with notice where required by applicable law.

6aChild safety and mandatory reporting

Auxerta is a provider of an electronic communication service or remote computing service within the meaning of 18 U.S.C. § 2258E and is required by 18 U.S.C. § 2258A to report apparent child sexual exploitation to the CyberTipline operated by the National Center for Missing & Exploited Children (“NCMEC”). This Section describes that process. It applies notwithstanding any other provision of this Policy.

(a) Circumstances of reporting. Where Auxerta obtains actual knowledge of facts or circumstances from which there is an apparent violation of the offences enumerated in 18 U.S.C. § 2258A(a)(2), Auxerta submits a report to the CyberTipline as soon as reasonably possible. NCMEC may make such report available to federal, state, local, tribal, or foreign law-enforcement agencies. Auxerta becomes aware of such circumstances principally by means of reports submitted by Users.

(b) Contents of a report. A report submitted under this Section may include: the reported content, including any image; the reported Account’s email address, handle, display name, and date of birth; the date on which the Account was created and its status; the IP address from which the Account was registered; the IP addresses, browser identification strings, and timestamps associated with recent authentication sessions; and the identity of the User who submitted the report.

(c) Preservation. As required by 18 U.S.C. § 2258A(h), Auxerta preserves the contents of a report, and any images or data associated with it, for the period prescribed by that provision. Such preserved material is retained notwithstanding any subsequent deletion of the entry, the image, or the Account, and a request for erasure under Section 9 does not extend to it.

(d) Absence of notice. Auxerta does not notify a User that a report concerning that User’s Account has been submitted. Notification would frustrate the purpose of the report and may be prohibited by applicable law.

(e) Scope. This Section applies solely to apparent child sexual exploitation. It does not constitute a general channel for law-enforcement access, and requests of other kinds are addressed under “Legal and safety” in Section 6.

7Cookies and similar technologies

This Section constitutes our Cookie Use policy. Auxerta uses cookies and similar technologies, including browser local storage, to operate the Service and to remember your preferences. We use the following categories:

• Strictly necessary. Cookies and storage that are essential to the operation of the Service, including maintaining your session and authentication state and securing the Service. These cannot be disabled without impairing core functionality such as sign-in.
• Functional and preference. Cookies and storage that remember your preferences and prior interactions, such as your reduced-motion setting and the dismissal of first-run prompts.

Auxerta does not currently use third-party advertising cookies or cross-site tracking technologies. This may change in the future, in which case we will provide notice and, where required by applicable law, obtain your consent before deploying such technologies.

You may control or delete cookies through your browser settings, and you may clear local storage through your browser. Please note that disabling strictly necessary cookies or storage may prevent sign-in and other core features from functioning.

8Data retention

We retain Personal Information for as long as your Account remains active and for a limited period thereafter, after which it is deleted or de-identified. We may retain information for longer where necessary to comply with legal, regulatory, security, or moderation obligations, or to establish, exercise, or defend legal claims, subject to applicable legal, security, and moderation holds. When you delete Your Content or your Account, we remove the associated information within a reasonable period, except to the extent retention is required or permitted as described above and except for routine backups maintained for a limited period.

Works made in the studio. Deleting an entry that carries a work made in the studio, or deleting the Account, withdraws the work from display throughout the Service and deletes the stored snapshot of its underlying document. The still image and the animation are held as separate files, and those files stop being served to anyone once no entry carries them, but are not at present erased from storage. This is the same limitation described in Section 4 of the Terms, and it is being addressed. A User may request erasure of a specific file by contacting Auxerta, and Auxerta will effect that erasure.

Certain records are retained for a defined and shorter period. A single-use link issued to confirm an email address expires forty-eight (48) hours after issue; a single-use link issued to reset a password expires one (1) hour after issue. Each is invalidated upon use, upon the issue of a replacement, and upon any change to the email address to which it was issued. A record of an authenticated session is invalidated upon sign-out and upon any reset of the Account password.

9Your rights and choices

Depending on your jurisdiction, you may have certain rights with respect to your Personal Information. Subject to applicable law, these may include the right to access, correct, delete, and export your Personal Information, the right to object to or restrict certain processing, and the right to withdraw consent. Within the Service, you may, at any time:

• edit or delete Your Content and delete your Account; Auxerta supports Account deletion and data export;
• withdraw your consent to AI Licensing on a prospective basis, as described in Section 5;
• publish or withdraw the day and month of your date of birth, at any time and with immediate effect, in the Account settings, as described in Section 2(a); and
• contact us at contact@auxerta.com to exercise any of your rights.

European Economic Area and United Kingdom (GDPR). Where the GDPR applies, you have the rights of access, rectification, erasure, restriction, data portability, and objection, and the right to lodge a complaint with your competent supervisory authority. Where processing is based on consent, you may withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

California (CCPA/CPRA). Where the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies, you have the rights to know, access, correct, and delete your Personal Information, and the right to opt out of the “sale” or “sharing” of Personal Information. Auxerta does not sell or share your Personal Information as those terms are defined under applicable law.

We will not discriminate against you for exercising any of these rights. We may take reasonable steps to verify your identity before responding to a request.

10Security

We employ administrative, technical, and organizational measures designed to protect Personal Information, including encryption in transit and at rest, hashing of passwords, and access controls that limit who may access data. Notwithstanding these measures, no method of transmission or storage is perfectly secure, and we cannot guarantee absolute security. We will notify you of security incidents affecting your Personal Information to the extent required by applicable law.

11Children’s privacy

The Service is intended for Users who are at least sixteen (16) years of age. The Service is not directed to, and may not be used by, children under the age of thirteen (13), consistent with the Children’s Online Privacy Protection Act (“COPPA”). We do not knowingly collect Personal Information from children under sixteen (16). If you believe that a child has provided us with Personal Information in violation of this Policy, please contact us at contact@auxerta.com and we will take appropriate steps to delete such information.

12International transfers

Auxerta is based in the United States, and we process Personal Information in the United States and in other jurisdictions in which we or our service providers operate. If you access the Service from outside the United States, you understand that your Personal Information may be transferred to, stored, and processed in a country whose data-protection laws may differ from those of your jurisdiction. Where we transfer Personal Information subject to the GDPR outside the European Economic Area or the United Kingdom, we implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, where required by applicable law.

13Changes to this policy

We may amend this Policy from time to time. If we make material changes, we will provide reasonable notice through the Service or by other appropriate means and will update the “Last updated” date set forth above. Your continued use of the Service after the effective date of any revised Policy constitutes your acceptance of the revised Policy, to the fullest extent permitted by applicable law.

14Contact

For questions regarding this Policy, to exercise your privacy rights, or for matters concerning the Terms generally, please contact us at contact@auxerta.com.