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Privacy Policy

Effective date: [EFFECTIVE DATE] · Last updated: [DATE]

⚠️ DRAFT — not yet legally binding. This is a working template pending review by legal counsel. Bracketed [PLACEHOLDERS] must be completed. Do not rely on this document until this notice is removed.

1. Scope

This Privacy Policy explains how [LEGAL ENTITY NAME] ("we", "us") collects, uses, and protects information in connection with the xcube platform and APIs (the "Service"). It supplements, and is incorporated into, our Terms of Service.

2. Information We Process

3. How We Use Information

We process information to provide the Service (including chat and retrieval over your knowledge bases), to authenticate users, to meter and bill usage, to enforce limits and prevent abuse, to maintain security, and to comply with law. We do not sell your personal information.

4. Tenant Isolation

Customer Data is segregated per organization. Access controls and row-level security are used so that one organization's data is not exposed to another.

5. Model Processing & Subprocessors

To generate responses and embeddings, prompts and relevant context are sent to model providers and infrastructure subprocessors that operate on our behalf. [LIST OF SUBPROCESSORS / MODEL PROVIDERS AND REGIONS — to be completed.] For on-premise deployments, processing occurs within the customer's environment as configured.

6. Data Retention

Customer Data is retained while your account is active and as needed to provide the Service. Conversation-scoped uploads may be deleted when the associated conversation is deleted. [SPECIFIC RETENTION PERIODS AND DELETION SLAs — to be completed.]

7. Security

We use technical and organizational measures including encryption in transit, access controls, tenant isolation, and secret encryption at rest for integration credentials. No method of transmission or storage is perfectly secure.

8. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, export, or delete personal information, and to object to or restrict certain processing. [HOW TO EXERCISE RIGHTS / DPO CONTACT / LEGAL BASES (e.g. GDPR) — to be completed.]

9. International Transfers

[CROSS-BORDER TRANSFER MECHANISMS, IF APPLICABLE — to be completed.]

10. Changes

We may update this Policy; material changes will be communicated through the Service or by other reasonable means.

11. Contact

Privacy questions: [PRIVACY CONTACT EMAIL].