Privacy Policy

Effective Date: Feb 15, 2025
Last Updated: Mar 31, 2026
Version: 1.2

INTRODUCTION

Aurynion LLC (“Aurynion,” “we,” “us,” or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit or use our website located at https://www.aurynion.com (the “Site”) or any services offered through the Site (“Services”).

This policy applies to all users of our Site, including visitors, registered users, and customers. It should be read alongside our:

• Terms of Use
• Cookie Policy
• AI Usage Policy

We serve users primarily in the United States, with additional users in the European Union, United Kingdom, and other regions. Where applicable, this policy addresses the requirements of:

• The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• The EU General Data Protection Regulation (GDPR)
• The UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018
• The Children’s Online Privacy Protection Act (COPPA)
• Applicable US state privacy laws including those of Virginia, Colorado, Connecticut, and Texas

If you do not agree with this policy, please discontinue use of our Site and Services.

TABLE OF CONTENTS

1. Who We Are and How to Contact Us
2. Information We Collect
3. How We Collect Your Information
4. How We Use Your Information
5. Legal Basis for Processing
6. Cookies and Tracking Technologies
7. AI and Automated Processing
8. How We Share Your Information
9. International Data Transfers
10. Data Retention
11. Data Security
12. Children’s Privacy
13. Your Privacy Rights
14. California Privacy Rights (CCPA / CPRA)
15. European Union and UK Privacy Rights (GDPR / UK GDPR)
16. Other US State Privacy Rights
17. Third-Party Links and Services
18. Changes to This Privacy Policy
19. Contact Us

1. WHO WE ARE AND HOW TO CONTACT US

Aurynion LLC is the data controller responsible for your personal information collected through this Site.

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

2. INFORMATION WE COLLECT

We collect the following categories of personal information:

2.1 Information You Provide Directly

• Account and Registration Information: Name, email address, username, password, and other details provided when creating an account
• Profile Information: Any additional information you choose to add to your profile
• Communications: Messages, inquiries, feedback, or other content you submit to us through contact forms, email, or customer support channels
• Payment Information: Billing name, address, and payment card details processed through our secure third-party payment processors. Aurynion does not store full payment card details directly
• User-Generated Content: Any content, including text, images, or files, that you submit, post, or upload to the Site

2.2 Information We Collect Automatically

When you visit our Site, we automatically collect certain technical and usage information, including:

• Device Information: Device type, operating system, browser type and version, and unique device identifiers
• Log Data: IP address, pages visited, time and date of visit, time spent on pages, referring URLs, and clickstream data
• Usage Data: Features used, search queries entered, interactions with content, and navigation paths through the Site
• Location Data: General geographic location derived from your IP address
• Cookie and Tracking Data: Information collected through cookies and similar technologies as described in our Cookie Policy

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Social Login Providers: If you choose to sign in using a third-party account such as Google or Facebook, we receive basic profile information from that provider in accordance with your privacy settings on that platform
• Analytics Providers: Aggregated and anonymized usage data from providers such as Google Analytics
• Advertising Partners: Information about your interactions with our advertisements displayed on third-party platforms
• AI Service Providers: Data returned from third-party AI tools we use in the delivery of our Services, as described in our AI Usage Policy

2.4 Sensitive Personal Information

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data. Please do not submit such information through our Site. If you do submit sensitive information, you consent to our processing it in accordance with this policy.

3. HOW WE COLLECT YOUR INFORMATION

We collect your information through the following means:

• Directly from you when you register, contact us, submit content, or use our Services
• Automatically through cookies, tracking technologies, and server logs when you browse our Site
• From third parties such as social login providers, analytics platforms, advertising partners, and AI service providers
• Through our AI tools when you interact with AI-powered features on our Site, as further described in our AI Usage Policy

4. HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

Purpose	Description
Service Delivery	To provide, operate, and maintain the Site and Services
Account Management	To create and manage your user account
Communications	To respond to your inquiries, provide customer support, and send service-related notices
Personalization	To personalize your experience and deliver relevant content
AI-Powered Features	To operate AI tools including content recommendations, search improvement, and customer support automation
Analytics and Improvement	To understand how users interact with our Site and improve its functionality and content
Marketing and Advertising	To send promotional communications where you have given consent or where we have a legitimate interest, and to measure the effectiveness of our marketing campaigns
Security and Fraud Prevention	To detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities
Legal Compliance	To comply with applicable legal obligations, enforce our Terms of Use, and protect the rights, property, and safety of Aurynion, our users, and others
Research and Development	To develop new features, products, and services, including the improvement of AI systems where data has been appropriately anonymized

We will not use your personal information for purposes that are incompatible with those listed above without first providing you with notice and, where required, obtaining your consent.

5. LEGAL BASIS FOR PROCESSING

This section applies primarily to users in the European Union and United Kingdom under GDPR and UK GDPR. For US users, our processing is governed by applicable federal and state privacy laws as described in Sections 14 and 16.

Processing Activity	Legal Basis
Account creation and service delivery	Performance of a Contract (Art. 6(1)(b) GDPR)
Personalization and marketing cookies	Consent (Art. 6(1)(a) GDPR)
Analytics using anonymized data	Legitimate Interests (Art. 6(1)(f) GDPR)
Fraud detection and security	Legitimate Interests (Art. 6(1)(f) GDPR)
AI-powered features with consent	Consent (Art. 6(1)(a) GDPR)
AI fraud detection and security	Legitimate Interests (Art. 6(1)(f) GDPR)
Legal compliance and obligations	Legal Obligation (Art. 6(1)(c) GDPR)
Responding to legal claims	Legitimate Interests (Art. 6(1)(f) GDPR)

Where we rely on legitimate interests as our legal basis, we have assessed that our interests are not overridden by your rights and freedoms. You have the right to object to processing based on legitimate interests at any time by contacting us at privacy@aurynion.com.

6. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies on our Site. A full description of the types of cookies we use, their purposes, and how to manage your preferences is set out in our Cookie Policy.

Your cookie preferences can be managed at any time through the Cookie Settings panel accessible in the footer of our Site.

7. AI AND AUTOMATED PROCESSING

We use both proprietary and third-party AI technologies as part of our Services. A full description of how AI is used, the data involved, and your rights regarding AI processing is set out in our AI Usage Policy.

Key points relevant to this Privacy Policy include:

• AI tools may process personal data for personalization, security, and service improvement purposes
• We do not use personal data to train or fine-tune our 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 models
• 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, contest the decision, and express your point of view. Contact privacy@aurynion.com to exercise these rights

8. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties. We may share your information in the following circumstances:

8.1 Service Providers and Processors

We share personal information with trusted third-party service providers who assist us in operating the Site and delivering our Services. These providers are bound by Data Processing Agreements (DPAs) and are only permitted to process your data for specified purposes under our instruction.

Categories of service providers include:

• Cloud hosting and infrastructure providers
• Analytics and performance monitoring providers
• Payment processing providers
• Email and communications providers
• Customer support platforms
• AI and machine learning service providers
• Advertising and marketing platforms
• Consent management providers

8.2 Third-Party AI Providers

As described in our AI Usage Policy, we share limited data with third-party AI service providers solely for the purposes of delivering AI-powered features. All such providers are bound by DPAs and applicable data protection law.

8.3 Business Transfers

If Aurynion is involved in a merger, acquisition, asset sale, or other business transaction, your personal information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

8.4 Legal Requirements and Protection of Rights

We may disclose your personal information where required to:

• Comply with a legal obligation, court order, or lawful government request
• Enforce our Terms of Use or other agreements
• Protect the rights, property, or safety of Aurynion, our users, or the public
• Detect, prevent, or address fraud, security, or technical issues

8.5 With Your Consent

We may share your information with third parties where you have given us explicit consent to do so.

8.6 Aggregated and Anonymised Data

We may share aggregated or anonymized data that does not identify you personally with third parties for research, analytics, or business purposes.

9. INTERNATIONAL DATA TRANSFERS

Aurynion is based in the United States. If you are accessing our Site from outside the United States, including from the European Union or United Kingdom, your personal information will be transferred to and processed in the United States and potentially other countries.

We ensure that all international transfers of personal data are made with appropriate safeguards in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission for transfers from the EU
• UK International Data Transfer Agreements (IDTAs) for transfers from the United Kingdom
• Data Processing Agreements (DPAs) with all third-party recipients of personal data
• Transfers only to countries or organizations that provide an adequate level of protection recognized under applicable law

For more information about the safeguards in place for your data transfers, contact us at privacy@aurynion.com.

10. DATA RETENTION

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting obligations.

Our general retention approach is as follows:

Data Category	Retention Period
Account and registration data	Duration of account plus 6 years following closure
Communications and support records	6 years from date of communication
Transaction and billing records	6 years as required by applicable law
Usage and analytics data	12 months in identifiable form; retained in anonymized form indefinitely
Cookie consent records	1 year or as required by applicable law
AI interaction data	12 months unless anonymized for improvement purposes
Legal hold data	Duration of relevant legal proceedings plus 6 years

When personal information is no longer required, we securely delete or anonymize it in accordance with our data deletion procedures.

To request deletion of your personal information, please refer to Section 13 of this policy.

11. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, destruction, alteration, or disclosure. These measures include:

• Encryption of data in transit using TLS and at rest where applicable
• Access controls and authentication requirements for all systems storing personal data
• Regular security assessments and vulnerability testing
• Staff training on data protection and information security
• Incident response procedures including data breach notification protocols

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, we will:

• Notify the relevant supervisory authority within 72 hours of becoming aware of the breach where required under GDPR
• Notify affected users without undue delay where the breach is likely to result in a high risk to their rights and freedoms
• Notify affected US users in accordance with applicable state data breach notification laws

12. CHILDREN’S PRIVACY

Our Site and Services are not directed at children under the age of 13. We do not knowingly collect personal information from children under 13 years of age.

If we become aware that we have inadvertently collected personal information from a child under 13 without appropriate parental consent, we will take immediate steps to delete that information from our systems.

If you believe that a child under 13 has provided us with personal information, please contact us immediately at privacy@aurynion.com.

For users between the ages of 13 and 16 in the European Union, we rely on parental or guardian consent where required by applicable law.

13. YOUR PRIVACY RIGHTS

Depending on your location, you may have the following rights regarding your personal information:

Right	Description
Right of Access	Request a copy of the personal information we hold about you
Right to Rectification	Request correction of inaccurate or incomplete personal information
Right to Erasure	Request deletion of your personal information, subject to legal obligations
Right to Restriction	Request that we limit the processing of your personal information
Right to Data Portability	Receive your personal information in a structured, machine-readable format
Right to Object	Object to processing based on legitimate interests or for direct marketing
Right to Withdraw Consent	Withdraw consent at any time where processing is based on consent
Right Against Automated Decisions	Request human review of automated decisions that significantly affect you

How to Submit a Rights Request

To exercise any of the above rights, contact us at:

• Email: privacy@aurynion.com with the subject line “Privacy Rights Request”
• Postal Address: Aurynion LLC, 228 Park Ave S / PMB 289706 New York, NY 10003-1502

We will respond to all verified 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 of the extension.

We may need to verify your identity before processing your request. We will not charge a fee for reasonable requests but reserve the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests.

14. CALIFORNIA PRIVACY RIGHTS (CCPA / CPRA)

This section applies to residents of California and supplements the information provided elsewhere in this policy.

14.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined under the CCPA:

Category	Examples	Collected
Identifiers	Name, email address, IP address, account username	Yes
Personal Records	Billing address, payment information	Yes
Protected Classifications	Age range for COPPA compliance only	Limited
Commercial Information	Purchase history, transaction records	Yes
Internet or Network Activity	Browsing history on Site, search queries, interactions	Yes
Geolocation Data	General location derived from IP address	Yes
Inferences	Profiles derived from usage data for personalization	Yes
Sensitive Personal Information	Not intentionally collected	No

14.2 Purposes for Collection

Personal information is collected and used for the purposes described in Section 4 of this policy.

14.3 Your California Rights

As a California resident, you have the following rights:

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, our business purposes, and the categories of third parties with whom we share it
• Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt Out of Sale or Sharing: We do not sell personal information. Where we share personal information with advertising or AI partners in ways that may constitute sharing under CPRA, you have the right to opt out via our Cookie Settings panel or by clicking “Do Not Sell or Share My Personal Information” [link]
• Right to Limit Use of Sensitive Personal Information: Where applicable, request that we limit the use of sensitive personal information to necessary purposes
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights

14.4 Shine the Light

California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, contact us at privacy@aurynion.com.

14.5 How to Submit a California Rights Request

Submit requests by:

• Email: privacy@aurynion.com with subject line “California Privacy Request”
• Online: [Privacy Rights Portal Link]

We will respond within 45 days of receipt, with a possible extension of a further 45 days where necessary.

15. EUROPEAN UNION AND UK PRIVACY RIGHTS (GDPR / UK GDPR)

This section applies to users in the European Union and United Kingdom and supplements the information provided elsewhere in this policy.

15.1 Data Controller

Aurynion LLC acts as the data controller for personal information collected through the Site. Contact details are provided in Section 1.

15.2 Your GDPR Rights

In addition to the rights set out in Section 13, EU and UK users have the following specific rights under GDPR and UK GDPR:

• Right to Lodge a Complaint: You have the right to lodge a complaint with your local Data Protection Authority (DPA) if you believe we have not handled your personal information in accordance with applicable law
  • EU users: locate your national DPA at https://www.edpb.europa.eu
  • UK users: Information Commissioner’s Office at https://ico.org.uk
• Right Not to Be Subject to Automated Decisions: As described in our AI Usage Policy, you have the right not to be subject to solely automated decisions that produce legal or similarly significant effects, and to request human review of any such decision

15.3 International Transfers from the EU and UK

As described in Section 9, transfers of personal data from the EU and UK to the United States are made under Standard Contractual Clauses (SCCs) or UK International Data Transfer Agreements (IDTAs) as applicable. Copies of relevant transfer mechanisms can be requested by contacting privacy@aurynion.com.

16. OTHER US STATE PRIVACY RIGHTS

Residents of the following states have privacy rights under their respective state laws. These rights are substantially similar to those described in Sections 13 and 14 and include rights of access, correction, deletion, portability, and opt-out of certain processing activities:

State	Applicable Law
Virginia	Consumer Data Protection Act (VCDPA)
Colorado	Colorado Privacy Act (CPA)
Connecticut	Connecticut Data Privacy Act (CTDPA)
Texas	Texas Data Privacy and Security Act (TDPSA)
Oregon	Oregon Consumer Privacy Act (OCPA)
Montana	Montana Consumer Data Privacy Act (MCDPA)

To exercise your rights under applicable state law, contact us at privacy@aurynion.com with the subject line “State Privacy Request” and include your state of residence.

We will respond within the timeframe required by your state’s applicable law.

17. THIRD-PARTY LINKS AND SERVICES

Our Site may contain links to third-party websites, services, and applications that are not operated or controlled by Aurynion. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices.

We encourage you to review the privacy policies of any third-party services you access through our Site. The inclusion of a link does not constitute an endorsement by Aurynion of that third party or their privacy practices.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory guidance.

When material changes are made, we will:

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

We encourage you to review this policy periodically. Your continued use of the Site following notice of any changes constitutes your acknowledgment of the updated policy.

19. CONTACT US

If you have any questions, concerns, or complaints about this Privacy Policy or our data 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 complaints, you may also contact your State Attorney General’s office.

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