AI Usage Policy

Effective Date: Feb 15, 2025
Last Updated: Mar 31, 2026
Version: 1.1

INTRODUCTION

This AI Usage Policy (“AI Policy”) describes how Aurynion LLC (“Aurynion,” “we,” “us,” or “our”) uses artificial intelligence technologies in the operation of our website located at https://www.aurynion.com (the “Site”) and the rules governing users’ interaction with any AI-powered features we provide.

This policy applies to:

• All AI tools developed and operated by Aurynion
• All third-party AI services integrated into our platform
• All users of our Site and Services

This policy forms part of our broader legal framework alongside our Privacy Policy, Terms of Use, and Cookie Policy. In the event of any conflict between this AI Policy and those documents, this AI Policy takes precedence with respect to AI-specific matters.

1. HOW Aurynion USES AI

1.1 Our Own AI Tools

Aurynion has developed and operates proprietary AI systems used for the following purposes:

AI Function	Purpose	Personal Data Involved
Content Personalization	Tailoring Site content to user interests and behavior	Yes — usage behavior and preferences
Search and Recommendation	Improving search relevance and content discovery	Yes — search queries and interaction data
Customer Support Assistance	Supporting or automating responses to user queries	Yes — submitted query content
Fraud and Security Detection	Identifying suspicious or unauthorized activity patterns	Yes — account and usage data
Analytics and Insights	Understanding aggregate usage patterns across the Site	Anonymized or pseudonymized data

1.2 Third-Party AI Services

We integrate AI tools provided by third-party vendors. These providers are bound by Data Processing Agreements (DPAs) and are required to handle all data in accordance with applicable law, including GDPR and CCPA.

Provider	AI Service	Purpose	Data Shared	Privacy Policy
[Provider Name]	[Service Name]	[Purpose]	[Data Type]	[Link]
[Provider Name]	[Service Name]	[Purpose]	[Data Type]	[Link]

All third-party links included in this policy do not constitute an endorsement by Aurynion of those third parties or their services.

1.3 What AI Does Not Do on Our Platform

We are committed to transparency regarding the boundaries of our AI use:

• AI does not make final decisions on legally significant matters such as credit, employment, or access to services without human review
• AI does not access your data outside of the purposes stated in this policy
• AI-generated outputs are not guaranteed to be accurate and should not be relied upon as professional advice
• We do not sell AI-derived insights about individual users to third parties

2. AI AND YOUR PERSONAL DATA

2.1 Legal Basis for AI Processing

Where AI processing involves personal data, we rely on the following legal bases:

Processing Activity	Legal Basis
Personalization with cookie consent	Consent (GDPR Art. 6(1)(a))
Fraud detection and security	Legitimate Interests (GDPR Art. 6(1)(f))
Service improvement using anonymized data	Legitimate Interests (GDPR Art. 6(1)(f))
Contractual service delivery	Performance of Contract (GDPR Art. 6(1)(b))

For US users, processing is governed by applicable federal and state privacy laws, including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other state privacy statutes where applicable.

2.2 AI Model Training

Aurynion takes the following position on the use of user data for AI model training:

• Aurynion does not use user-submitted content or personal data to train or fine-tune its own AI models
• Where training data is used, it is anonymized and aggregated prior to use
• We do not share identifiable user data with third-party AI providers for the purpose of training their foundational or generative AI models
• Users have the right to object to their data being used for AI model training at any time — see Section 5 of this policy for how to exercise this right

2.3 Automated Decision-Making and Profiling

Pursuant to GDPR Article 22 and applicable US state privacy laws, we disclose the following regarding automated decision-making on our platform:

We do not engage in solely automated decision-making that produces legal or similarly significant effects on users.

Where automated decisions are made:

• You have the right to request human review of any automated decision affecting you
• You have the right to contest such decisions
• You have the right to express your point of view before a final decision is reached

To exercise any of these rights, contact us at privacy@aurynion.com.

2.4 AI-Generated Content Disclosure

Where our Site or Services present content that has been generated or significantly assisted by AI, Aurynion will:

• Label or disclose AI-generated content where it is material to your use of the Site
• Ensure AI-generated content is reviewed for accuracy where used in professional or advisory contexts
• Not misrepresent AI-generated content as human-authored expert opinion

3. USER OBLIGATIONS REGARDING AI

3.1 Prohibited Uses of AI Features

When interacting with any AI-powered feature on our Site, users must not:

• Use AI features to generate illegal, harmful, defamatory, discriminatory, or deceptive content
• Attempt to manipulate, reverse engineer, jailbreak, or circumvent the limitations or safeguards of our AI systems
• Submit other individuals’ personal data to AI features without their knowledge and consent
• Use AI outputs to engage in spam, phishing, fraud, or any other unauthorized or unlawful activity
• Use AI features to violate the intellectual property rights of any third party
• Represent AI-generated content as human-created in contexts where this distinction is material or where our platform requires original human authorship

3.2 Prohibition on AI Scraping and Automated Data Extraction

The following are strictly prohibited without prior written authorization from Aurynion:

• Using AI bots, crawlers, or automated systems to extract, scrape, or harvest any content from the Site
• Using Site content, user data, or any Aurynion materials to train, fine-tune, develop, or improve any AI or machine learning model
• Deploying large language models (LLMs) or AI agents to interact with the Site in a manner that circumvents normal user access patterns or places unreasonable load on our systems
• Using AI-powered automated scripts to access, query, or interact with Site features in place of genuine human interaction

Violations of this section may result in immediate account suspension or termination and may constitute a breach of the Computer Fraud and Abuse Act (CFAA), applicable EU law, or other relevant legislation.

3.3 User-Submitted AI-Generated Content

If you submit content to our Site that was generated using third-party or external AI tools:

• You remain fully responsible for that content and its accuracy
• You warrant that the content does not infringe the intellectual property or other rights of any third party
• You must not represent AI-generated content as original human work where our platform specifically requires human authorship
• Aurynion reserves the right to remove AI-generated content that violates these terms, our Terms of Use, or applicable law

4. ACCURACY, RELIABILITY, AND DISCLAIMERS

AI systems, including those operated by Aurynion, have known limitations that users should be aware of:

• AI outputs may contain errors, inaccuracies, or outdated information, commonly referred to as hallucinations
• AI-generated content does not constitute legal, medical, financial, or any other form of professional advice
• Aurynion makes no warranty, express or implied, as to the accuracy, completeness, or fitness for purpose of any AI-generated output
• You should independently verify any AI-generated information before relying on it for any consequential or professional decision

For AI-related limitation of liability, please also refer to the Limitation of Liability provisions in our Terms of Use.

5. YOUR RIGHTS REGARDING AI USE

5.1 All Users

Right	How to Exercise
Opt-out of AI personalization	Cookie Settings panel or email privacy@aurynion.com
Opt-out of AI model training	Email privacy@aurynion.com with subject line: “AI Training Opt-Out”
Request human review of an automated decision	Email privacy@aurynion.com with subject line: “Human Review Request”
Request information about AI decisions affecting you	Email privacy@aurynion.com

We will respond to all rights requests within 30 days of receipt. Where a request is complex or numerous, we may extend this period by a further 30 days and will notify you accordingly.

5.2 European Union and UK Users (GDPR / UK GDPR)

In addition to the rights listed above, EU and UK users have rights under GDPR Article 22 including:

• The right not to be subject to solely automated decisions with significant legal or similarly significant effects
• The right to obtain human intervention in any automated decision-making process
• The right to express your point of view and to contest any automated decision made about you
• The right to lodge a complaint with your local Data Protection Authority
  • EU users: locate your national DPA at https://www.edpb.europa.eu
  • UK users: Information Commissioner’s Office at https://ico.org.uk

5.3 California Users (CCPA / CPRA)

• You have the right to opt out of automated profiling used for targeted advertising purposes
• You may request disclosure of the logic involved in automated decisions that significantly affect you
• You have the right to opt out of the sale or sharing of personal information processed by AI systems
• Submit requests via our Privacy Rights Portal or by emailing privacy@aurynion.com

5.4 Other US State Privacy Laws

Users in Virginia, Colorado, Connecticut, Texas, and other states with applicable privacy legislation may have rights regarding automated decision-making and AI-based profiling. Please refer to our Privacy Policy for full details.

6. AI GOVERNANCE AND ACCOUNTABILITY

Aurynion is committed to the responsible, ethical, and transparent use of AI across our platform:

• We conduct periodic AI impact assessments for high-risk AI applications
• We maintain human oversight of AI systems used in any consequential decision-making processes
• We work actively to identify and mitigate bias in AI models we develop or deploy
• We follow applicable AI regulations including the EU AI Act for EU-facing services and evolving US federal and state AI guidance
• Third-party AI vendors are selected based on their demonstrated commitments to data protection, ethical AI development, and regulatory compliance

7. CHILDREN AND AI

Consistent with our Privacy Policy and our obligations under the Children’s Online Privacy Protection Act (COPPA):

• AI-powered features on our Site are not directed at children under the age of 13
• We do not knowingly use AI to collect, process, or profile the personal data of children under 13
• If you believe a child has interacted with our AI systems or that their data has been processed without appropriate consent, please contact us immediately at privacy@aurynion.com.

8. UPDATES TO THIS POLICY

AI technology and the regulatory landscape governing its use are evolving rapidly. We will update this policy periodically to reflect:

• New AI tools, features, or third-party integrations we deploy
• Changes in applicable AI law or regulatory guidance, including the EU AI Act and US federal and state developments
• Material changes to how we process personal data using AI systems

When material changes occur, we will:

• Update the Last Updated date at the top of this policy
• Notify registered users by email for significant changes
• Post a prominent notice on our Site

We encourage you to review this policy regularly.

9. CONTACT US

For questions, concerns, rights requests, or complaints related to our AI practices, please contact us:

Aurynion LLC
Address: 228 Park Ave S / PMB 289706 New York, NY 10003-1502
Email: privacy@aurynion.com
Phone: +1 (212) 634-9350
Website: https://www.aurynion.com

For EU and UK data protection matters, you may also contact our Data Protection Representative at: privacy@aurynion.com

For US privacy-related complaints, you may contact your State Attorney General’s office.

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This AI Usage Policy should be read in conjunction with our Privacy Policy, Cookie Policy and Terms of Use.