Privacy Policy of the Sanero.ai Service

Effective date: 29 June 2026·Version 1.0

1General provisions

1.1. This Privacy Policy (the “Policy”) sets out the procedure for processing and protecting the personal data of Users of the Sanero.ai Service (the “Service”) and describes the categories of data processed, the purposes and legal bases of processing, the categories of recipients, retention periods, security measures, and the rights of data subjects.

1.2. The Policy is an integral part of the Terms of Use (Public Offer). Terms not defined in the Policy are used with the meaning established by the Terms of Use.

1.3. By using the Service, the User confirms that they have reviewed this Policy. If the User does not agree with the conditions of processing, they must refrain from using the Service.

1.4. The Operator determines the purposes and means of processing Users’ personal data and acts as the controlling person (controller) in respect of such processing. The engaged Third-party suppliers act predominantly as processors (sub-processors) on the instructions and under the responsibility of the Operator, except where they act as independent controllers by virtue of their own terms.

2Categories of data processed

The Operator processes the following categories of data:

2.1. Account and profile data: e-mail address; username (if provided); display name, profession, user traits, “about” information (bio); profile image (avatar); interface language and user settings for the interface and behaviour of the Service.

2.2. Authentication and security data: an irreversible cryptographic hash of the password; the encrypted two-factor-authentication secret and hashed backup codes (where two-factor authentication is enabled); technical anti-brute-force indicators (counters of failed attempts, temporary lockout); service parameters for session revocation.

2.3. Content data: the text of chats and messages; uploaded attachments and text extracted from documents; generated images and video; search and research queries and related service data; ratings of answers (“like”/“dislike”); organisational elements (folders, chat titles).

2.4. Usage and charging data (telemetry): information about requests — the type of request, the identifier and name of the Model used, the operating mode, the volume of tokens processed, the calculated cost, timestamps, generation duration, execution status, and the source of the charge (the subscription limit or the Top-up balance).

2.5. Technical and security-log data: the IP address of the last login and the timestamp of the login; the login-attempt log containing the IP address and information about the client software (user-agent); service security logs and (in respect of administrative actions) audit logs.

2.6. Subscription and balance data: the tariff plan and subscription status, the subscription validity period, deduction-mode parameters, and the history and state of the Top-up balance.

2.7. Support-request data: the subject and content of requests, the messages of correspondence with support, and the files attached to them.

2.8. Payment data. When payment is connected, payment processing is carried out by a third-party payment provider. The Operator does not store full payment-credential details (card numbers and similar data); the Operator processes only the information necessary to record the fact and parameters of a payment (see Section 6 of this Policy and Section 14 of the Terms of Use).

The Operator does not deliberately request special categories of data. The User should not enter into the Service special-category data or third-party information without a lawful basis; responsibility for such entry rests with the User.

3Purposes and legal bases of processing

The Operator processes data for the listed purposes on the following legal bases (taking into account applicable data-protection law, including the EU General Data Protection Regulation — GDPR):

3.1. Provision of the Service and performance of the contract (registration and maintenance of the account, processing of requests and production of Results, billing and usage accounting, support) — basis: performance of the contract with the User, and taking steps to conclude it.

3.2. Security, prevention of abuse and fraud, moderation (protection against password guessing, detection of unlawful and prohibited use, maintenance of security logs, handling of complaints) — basis: the legitimate interests of the Operator and third parties, and, as regards legal requirements, compliance with a legal obligation.

3.3. Maintaining operability and improving the quality of the Service (diagnostics, usage analytics in anonymised or aggregated form, improving the accuracy and quality of Results) — basis: the legitimate interests of the Operator.

3.4. Compliance with legal requirements (responses to lawful requests of authorised bodies, tax and accounting records where there is a corresponding obligation) — basis: compliance with a legal obligation.

3.5. Service-related communications (service notifications, informing about changes to the conditions) — basis: performance of the contract and legitimate interests; marketing messages, if sent, are sent on the basis of consent, which may be withdrawn.

3.6. Use of cookies and similar technologies — in accordance with Section 10 of this Policy; non-strictly-necessary technologies are applied on the basis of consent.

When carrying out processing on the basis of legitimate interests, the Operator observes a balance between such interests and the rights of the User; the User has the right to object to such processing in the manner set out in Section 8.

4Sources of data

4.1. Data is received predominantly directly from the User (on registration, profile setup, use of the features of the Service, contacting support) and is generated automatically in the course of using the Service (telemetry, technical and security logs).

5Automated processing and moderation

5.1. The Service applies automated means to ensure security and moderation, including to detect indicators of unlawful or prohibited content. Upon the triggering of such indicators, and in other cases necessary for moderation, security, prevention of abuse and compliance with the law, authorised persons of the Operator are entitled, automatically and/or manually, to access the relevant content and correspondence and to review them. Access is carried out proportionately and is limited to the said purposes.

5.2. The Operator does not take, in respect of the User, decisions producing legal or other significant effects solely on the basis of automated processing without human involvement, with the exception of measures to protect the Service (for example, automatic temporary restriction upon detection of abuse), which may be appealed by the User by contacting the Operator.

6Categories of recipients and cross-border transfer

6.1. For the operation of the Service, data may be transferred to the following categories of recipients (sub-processors) acting as Third-party suppliers. The specific names constitute the Operator’s trade secret and are not disclosed:

  • third-party AI-model providers — for processing requests and producing Results;
  • infrastructure and hosting providers — for hosting, storing and processing data;
  • search services — for performing web-search and research functions;
  • payment providers — for processing payments (where payment is connected);
  • persons providing the Operator with auxiliary technical and analytical services — to the extent necessary for such services.

6.2. Data may be disclosed to authorised bodies and other persons where required by applicable law, to protect the rights and legitimate interests of the Operator, Users and third parties, and to a successor in the event of a reorganisation, transfer or sale of the Service.

6.3. The volume of data transferred to sub-processors is limited to what is necessary for the relevant purpose. In particular, when a request is processed, the content of the request and the necessary service parameters are transmitted to the relevant supplier.

6.4. Cross-border transfer. Sub-processors may be located outside the User’s country of residence, including in States that do not ensure an equivalent level of data protection. In such cases the Operator takes reasonable and applicable measures to ensure an appropriate level of protection for the transferred data in accordance with applicable law (including the use of legally provided transfer mechanisms). Information about the measures applied is provided on request through the contacts specified in the Policy.

7Retention periods

7.1. Data is stored for no longer than is necessary for the purposes of processing for which it was obtained, or for the period established by applicable law.

7.2. Account and content data is stored for the duration of the account. Upon self-service deletion of the account by the User, the associated data is deleted in a cascading and irreversible manner, including chats and messages, attachments, usage data, research sessions, folders, the state and history of the Top-up balance, support requests and account-related service records; the avatar file is deleted from storage.

7.3. Exceptions from deletion. For the purposes of security, prevention of abuse, dispute resolution and compliance with legal requirements, the Operator is entitled to retain, for a limited, reasonably necessary period, certain security and audit records (in particular, the login-attempt log and the log of administrative actions), from which, where applicable, the direct identifiers of the deleted account are excluded. The login-attempt log is stored for a limited technical period and is subject to automatic purging.

7.4. Data processed on the basis of consent is stored until consent is withdrawn, unless another basis for its storage exists. Data subject to storage by law (for example, for accounting purposes where there is a corresponding obligation) is stored for the period established by law.

8Rights of data subjects

8.1. In respect of their personal data, the User has the rights granted by applicable law, including, depending on the jurisdiction:

  • the right to access the data and obtain a copy of it;
  • the right to rectify inaccurate and complete incomplete data;
  • the right to erasure of data (the “right to be forgotten”);
  • the right to restriction of processing;
  • the right to portability of data in a structured, machine-readable format;
  • the right to object to processing based on legitimate interests, and to object to processing for direct-marketing purposes;
  • the right to withdraw consent previously given, without prejudice to the lawfulness of processing carried out before the withdrawal;
  • the right to lodge a complaint with the competent supervisory authority for data protection.

8.2. Self-service exercise of rights in the interface of the Service. Some rights are exercised by the User independently and immediately:

  • Erasure of data — the User may independently delete their account through the interface of the Service; deletion entails the cascading and irreversible deletion of associated data to the extent described in Section 7, taking into account the exceptions provided for therein;
  • Portability (export) of data — the User may independently download their data in a machine-readable format (including profile details, chats and messages, usage records) through the interface of the Service.

8.3. Other rights are exercised by contacting the Operator through the contacts specified in the Policy. The Operator responds to a request within the time limits established by applicable law. For security purposes, the Operator may take reasonable measures to verify the identity of the applicant. The exercise of certain rights may be limited if it affects the rights of third parties or conflicts with the Operator’s obligations under the law.

9Data security

9.1. The Operator applies modern organisational and technical protection measures appropriate to the nature of the data processed and the current state of the art.

9.2. Users’ data is stored in encrypted form (encryption at rest) and transmitted over secure, encrypted communication channels (encryption in transit) using modern, industry-standard cryptography. Passwords are stored solely as irreversible cryptographic hashes and cannot be restored to their original form; two-factor-authentication secrets are stored in encrypted form.

9.3. Access to data is granted to a limited circle of authorised persons on a need-to-know basis and for the purposes provided for in this Policy and the Terms of Use. Measures of access control, logging and counteraction to unauthorised access are applied.

9.4. Despite the measures taken, no method of transmitting and storing data is absolutely secure; the Operator cannot guarantee absolute security but makes reasonable efforts to detect and respond to incidents in a timely manner in accordance with applicable law.

10.1. The Service uses cookies and similar technologies (browser local storage and other means of storing and reading data on the User’s device). This Section describes the technologies applied and is a constituent part of the Policy.

10.2. Categories of technologies applied:

(a) strictly necessary — ensure login to the account, session maintenance, security and the basic operability of the Service; without them the Service cannot function; applied on the basis of performance of the contract and legitimate interests and do not require consent;

(b) functional — save the User’s choices and settings (for example, interface language, theme, display preferences);

(c) analytical — when applied, help to understand the nature of use of the Service in anonymised or aggregated form for the purposes of diagnostics and quality improvement.

10.3. Legal basis and consent. Strictly necessary technologies are applied without consent. Functional and analytical technologies that are not strictly necessary are applied on the basis of the User’s consent, expressed through the consent-management tools (banner) on the first visit and changeable thereafter.

10.4. Management. The User can manage consent through the tools provided by the Service, as well as through their browser settings (including deletion and blocking of cookies). Disabling certain technologies may limit the availability of some features of the Service.

10.5. Certain technologies may be set by Third-party suppliers as part of the services they provide; their use is also subject to the terms of the respective suppliers. The specific names of the suppliers constitute the Operator’s trade secret and are not disclosed.

11Minors

11.1. The Service is intended for persons aged 18 or over and is not addressed to minors. The Operator does not knowingly collect the data of persons under 18. Upon discovering that data belongs to a minor, the Operator takes reasonable measures to stop the processing and delete such data.

12Changes to the Policy

12.1. The Operator is entitled to amend the Policy. The version in force, with an indication of the effective date and version, is published within the Service. The Operator notifies the User of material changes by a reasonable means before they take effect, where required by applicable law. Continued use of the Service after the changes take effect signifies agreement with the updated version to the extent that does not require separate consent.

13Contacts

13.1. On matters of personal-data processing and the exercise of data-subject rights, the User may contact the Operator: e-mail — saneroai4@gmail.com; Telegram — @velvixshoptg. The authority supervising data processing and the procedure for lodging a complaint are determined by the applicable law of the User’s place of residence.