1. Introduction and Scope

This Privacy Policy ("Policy") is issued by Persephonie, Inc., a Delaware corporation ("Persephonie," "Company," "we," "us," or "our"), and governs the collection, use, processing, storage, disclosure, and protection of personal information and data obtained through or in connection with the Persephonie visual AI decision tree platform, including all related websites, applications, services, application programming interfaces (APIs), tools, features, and functionalities (collectively, the "Service"). The Service enables users to submit questions, prompts, and other content for the purpose of generating visual decision trees, node-based analytical structures, branching outcome maps, and other visual AI outputs ("Tree Structures") powered by artificial intelligence models including but not limited to the Anthropic Claude API.

By accessing, browsing, registering for, or otherwise using the Service, you ("User," "you," or "your") acknowledge that you have read, understood, and agree to be bound by this Policy in its entirety. If you do not agree to the terms of this Policy, you must immediately cease all use of the Service and delete any account associated with the Service. This Policy applies to all Users of the Service regardless of geographic location, including but not limited to individuals located in the United States, the European Economic Area ("EEA"), the United Kingdom ("UK"), Switzerland, Canada, Australia, and all other jurisdictions from which the Service may be accessed.

This Policy is incorporated into and forms part of the Persephonie Terms of Service. Capitalized terms not defined herein shall have the meanings ascribed to them in the Terms of Service. In the event of any conflict between this Policy and the Terms of Service regarding privacy-related matters, this Policy shall control. Persephonie reserves the right to modify, amend, supplement, or replace this Policy at any time in accordance with Section 15 below.

The Service is designed to transform traditional text-based AI responses into interactive visual decision trees, enabling Users to explore branching pathways, compare outcomes, and navigate complex decisions through an intuitive node-based interface rather than consuming linear prose. The nature of this Service requires the processing of User-submitted content, including questions, contextual information, preferences, and other inputs necessary for the generation of Tree Structures. This Policy describes in detail how such information, along with all other categories of personal data, is handled throughout the data lifecycle.

2. Information We Collect

We collect information from and about Users through multiple channels and mechanisms in connection with the provision, maintenance, improvement, and protection of the Service. The categories of information we collect include, without limitation, the following:

2.1 Information You Provide Directly

Account Information. When you create a Persephonie account, we collect your full name, email address, username, password (stored in hashed form), profile photograph or avatar (if provided), and any other information you voluntarily submit during the registration process. If you authenticate using a third-party identity provider (such as Google, GitHub, or Apple), we receive your name, email address, and profile image from that provider in accordance with the permissions you grant during the authentication flow.

Payment and Transaction Information. If you subscribe to a paid tier of the Service (including Pro and Enterprise plans), we collect billing information necessary to process your transaction, including your name, billing address, and payment card details. Payment processing is handled by our third-party payment processor, Stripe, Inc. ("Stripe"). Persephonie does not directly store your full credit card number, debit card number, or bank account number on its servers. Stripe's collection and use of your payment information is governed by Stripe's own privacy policy, available at https://stripe.com/privacy. We do receive and store a truncated version of your card number (last four digits), card brand, expiration date, billing address, and transaction history for record-keeping, customer support, fraud prevention, and accounting purposes.

User Content and Decision Tree Inputs. The core functionality of the Service requires you to submit questions, prompts, decisions, scenarios, contextual information, and other content ("User Content") for the purpose of generating visual decision trees, branching outcome analyses, and node-based visual AI outputs. We collect, process, transmit, and store all User Content submitted to the Service, including but not limited to: the text of questions and prompts; follow-up queries; selections made within Tree Structures (such as clicking on specific nodes, expanding branches, or exploring particular pathways); annotations or notes added to tree nodes; shared or exported Tree Structures; and any feedback, ratings, or evaluations provided regarding the quality, accuracy, or usefulness of generated Tree Structures.

Communications. When you contact us for customer support, submit a bug report, provide feedback, respond to surveys, participate in research studies, or otherwise communicate with Persephonie, we collect the content of those communications along with associated metadata including timestamps, communication channel, and any attachments or supporting documentation you provide.

Professional and Employment Information. If you register for an Enterprise account or participate in sales discussions, we may collect your job title, employer name, department, professional role, company size, industry, and other business-related information relevant to providing Enterprise-tier services.

2.2 Information Collected Automatically

Device and Browser Information. When you access the Service, we automatically collect information about the device and software you use, including but not limited to: device type (desktop, laptop, tablet, mobile phone); operating system and version; browser type and version; screen resolution and display dimensions; device manufacturer and model; unique device identifiers (including advertising identifiers, hardware identifiers, and other persistent or non-persistent device identifiers); language and locale settings; time zone; and available system fonts and plugins. This information is collected through standard web technologies and may be used for analytics, security, compatibility, and service optimization purposes.

Log and Usage Data. We automatically record information about your interactions with the Service, including: IP address (both IPv4 and IPv6); access timestamps; pages and screens viewed; features accessed; clickstream data; navigation paths through the Service; referring and exit URLs; search queries entered within the Service; frequency and duration of visits; Tree Structures generated, viewed, shared, or exported; nodes clicked and branches explored within decision trees; session duration and activity patterns; error logs and crash reports; API call logs; and performance metrics. This log data is essential for maintaining, securing, and improving the Service and is processed on the basis of our legitimate interests and contractual necessity.

Location Information. We collect approximate geographic location information derived from your IP address, which may include your country, state or region, city, and postal code. We do not collect precise geolocation data (such as GPS coordinates) through the Service unless you explicitly grant such permission, which is not currently a feature of the Service. Approximate location data is used for analytics, compliance with geographic restrictions, content localization, fraud prevention, and regulatory compliance purposes.

Cookies and Similar Technologies. We use cookies, web beacons, pixel tags, local storage objects, and similar tracking technologies to collect information about your use of the Service. For detailed information about our use of these technologies, please refer to Section 13 (Cookies and Tracking Technologies) of this Policy.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including: identity verification services; fraud prevention and security services; analytics providers; advertising networks and partners; social media platforms (when you interact with our social media presence or use social login features); publicly available databases and directories; business data providers; other Users who invite you to collaborate on shared Tree Structures or refer you to the Service; and our business partners, affiliates, and subsidiaries. We may combine information received from third parties with information we collect directly from you or automatically through the Service to create a more complete profile, improve the accuracy of our records, enhance our ability to provide and personalize the Service, and for other purposes described in this Policy.

3. How We Use Your Information

We use the information we collect for the following purposes, each of which constitutes a legitimate and lawful basis for processing under applicable data protection laws:

3.1 Providing and Operating the Service

We use your information to provide, maintain, and operate the Service, including: creating and managing your account; authenticating your identity and verifying your credentials; processing your User Content and generating visual decision trees, branching outcome analyses, node-based visual AI outputs, and other Tree Structures; rendering interactive tree visualizations and enabling navigation through decision pathways; storing and retrieving your Tree Structures, conversation history, and preferences; enabling collaboration features such as shared trees and team workspaces; processing subscription payments and managing billing cycles; providing customer support and responding to inquiries; and delivering notifications, updates, and service-related communications.

3.2 Processing Transactions

We use your payment and billing information to process subscription payments, manage recurring charges, handle refunds and credits, prevent fraudulent transactions, comply with tax and accounting obligations, and maintain accurate financial records. Transaction data is shared with our payment processor, Stripe, solely for the purpose of completing and managing your transactions. We retain transaction records for the period required by applicable tax, accounting, and financial regulations, which may extend beyond the termination of your account.

3.3 Analytics and Performance

We use information about your use of the Service to understand how Users interact with the platform, identify usage patterns and trends, measure the effectiveness of features and functionality, diagnose technical issues and performance bottlenecks, conduct A/B testing and feature experimentation, generate aggregated statistical reports, and make data-driven decisions about product development, feature prioritization, and service improvements. Analytics processing may involve the use of third-party analytics tools as described in Section 14 of this Policy.

3.4 Improving AI and Decision Tree Generation

We use information derived from User interactions with the Service, including User Content, Tree Structure generation patterns, node selection data, branch exploration behavior, and feedback on AI-generated outputs, to improve and refine the artificial intelligence models, algorithms, and systems that power the Service. This includes improving the quality, accuracy, relevance, and diversity of generated decision trees; optimizing the structure, layout, and visual presentation of Tree Structures; enhancing the AI's ability to understand and respond to User questions across a wide range of domains and decision types; training and fine-tuning machine learning models; developing new AI capabilities and features; and conducting research and development related to visual AI output and node-based analytical frameworks. For detailed information about how User Content is processed for service improvement purposes, including applicable tier-based distinctions, please refer to Section 4 of this Policy.

3.5 Security and Fraud Prevention

We use your information to protect the security and integrity of the Service, our Users, and our systems, including: detecting, investigating, and preventing fraudulent, unauthorized, or illegal activity; identifying and mitigating security threats, vulnerabilities, and attacks; enforcing our Terms of Service and other policies; verifying account ownership and preventing unauthorized access; monitoring for abuse, spam, and other prohibited conduct; implementing rate limiting and other protective measures; and cooperating with law enforcement and regulatory authorities as required by law.

3.6 Legal Compliance

We use your information as necessary to comply with applicable laws, regulations, legal processes, and governmental requests, including: responding to subpoenas, court orders, and other legal process; fulfilling regulatory reporting obligations; establishing, exercising, or defending legal claims; complying with tax, accounting, and financial reporting requirements; meeting data retention obligations; and cooperating with regulatory investigations and audits.

3.7 Communications and Marketing

We use your contact information to send you service-related communications (such as account verification, transaction confirmations, security alerts, and policy updates), which are necessary for the operation of the Service and are not subject to opt-out. With your consent where required by applicable law, we may also send you promotional communications about new features, product updates, events, and other information we believe may be of interest to you. You may opt out of promotional communications at any time by following the unsubscribe instructions included in each email or by contacting us at the address provided in Section 16 of this Policy. Opting out of promotional communications will not affect your receipt of service-related communications.

4. Data Processing for Service Improvement

This Section provides detailed information about how Persephonie processes User Content and related data for the purpose of improving the Service, including the artificial intelligence models, algorithms, and systems that generate visual decision trees, node-based analyses, and other Tree Structures. PLEASE READ THIS SECTION CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION ABOUT HOW YOUR CONTENT MAY BE USED.

4.1 Purpose and Scope of Data Processing

The quality, accuracy, and usefulness of the visual decision trees and AI-generated outputs provided by the Service are directly dependent on the continuous improvement of the underlying AI models and algorithms. To provide and improve the Service, Persephonie processes User Content — including questions submitted for tree generation, contextual information provided in prompts, node selections and branch exploration patterns, Tree Structure interaction data, and feedback on generated outputs — for the purposes of: training, fine-tuning, and improving machine learning models; evaluating and benchmarking AI performance; improving the relevance, accuracy, and diversity of generated decision trees; optimizing Tree Structure layout, visual presentation, and node organization; developing new features and capabilities; conducting internal research on visual AI output methodologies; and improving the overall quality and reliability of the Service.

4.2 Anonymization and De-identification

When User Content is processed for service improvement purposes as described in this Section, Persephonie applies anonymization and de-identification techniques designed to remove or obscure personally identifiable information prior to use in model training, benchmarking, and research activities. These techniques may include, without limitation: removing names, email addresses, and other direct identifiers; stripping metadata that could be used to re-identify individuals; aggregating data across multiple Users to prevent identification of any single User; applying differential privacy techniques; tokenizing or hashing identifiable elements; and implementing access controls that restrict the use of processed data to authorized personnel and systems. NOTWITHSTANDING THE FOREGOING, PERSEPHONIE CANNOT GUARANTEE THAT ANONYMIZATION OR DE-IDENTIFICATION TECHNIQUES WILL BE EFFECTIVE IN ALL CIRCUMSTANCES OR THAT RE-IDENTIFICATION IS IMPOSSIBLE UNDER ALL SCENARIOS. BY USING THE SERVICE, YOU ACKNOWLEDGE AND ACCEPT THIS INHERENT LIMITATION.

4.3 Tier-Based Data Processing Distinctions

Persephonie offers multiple service tiers, each with distinct data processing terms regarding the use of User Content for service improvement:

Free Tier. User Content submitted through the Free tier of the Service may be used by Persephonie for all service improvement purposes described in this Section, including but not limited to AI model training, fine-tuning, benchmarking, research, and development. The processing of User Content for these purposes is an essential and integral component of the Free tier offering. The ability to use Free tier User Content for service improvement purposes enables Persephonie to provide the Free tier at no monetary cost to the User. ACCORDINGLY, USERS OF THE FREE TIER DO NOT HAVE THE ABILITY TO OPT OUT OF THE USE OF THEIR USER CONTENT FOR SERVICE IMPROVEMENT PURPOSES. USE OF THE FREE TIER CONSTITUTES ACCEPTANCE OF THIS DATA PROCESSING. If you do not wish for your User Content to be processed for service improvement purposes, you must upgrade to the Enterprise tier or cease using the Service.

Pro Tier. User Content submitted through the Pro tier of the Service may be used by Persephonie for all service improvement purposes described in this Section, including but not limited to AI model training, fine-tuning, benchmarking, research, and development. The processing of User Content for these purposes is an essential component of the Pro tier offering and enables Persephonie to provide the Pro tier at its current price point, which is significantly below the full cost of providing the Service on a per-User basis without the benefit of aggregate data-driven improvements. THE PRO TIER DOES NOT INCLUDE AN OPT-OUT MECHANISM FOR THE USE OF USER CONTENT FOR SERVICE IMPROVEMENT PURPOSES, AS SUCH PROCESSING IS INTEGRAL TO THE PROVISION OF THE SERVICE AT THE PRO TIER PRICE POINT. If you require that your User Content not be used for service improvement purposes, you must upgrade to the Enterprise tier.

Enterprise Tier. User Content submitted through the Enterprise tier of the Service is NOT used by Persephonie for AI model training, fine-tuning, or other service improvement purposes described in this Section, unless the Enterprise customer provides explicit, separate, written consent for such use. Enterprise tier data processing is governed by the Enterprise Data Processing Agreement ("DPA"), which is executed separately between Persephonie and each Enterprise customer. The Enterprise DPA may include additional data protection terms, processing restrictions, audit rights, and compliance certifications tailored to the Enterprise customer's requirements. Enterprise customers who wish to contribute their data to service improvement efforts may do so through an explicit opt-in mechanism documented in the Enterprise DPA.

4.4 Legal Basis for Data Processing

The processing of User Content for service improvement purposes is conducted on the following legal bases: (a) contractual necessity, as such processing is an integral part of the Service that Users agree to when accepting the Terms of Service and creating an account; (b) legitimate interests of Persephonie in improving the quality, accuracy, and reliability of the Service, developing new features and capabilities, and advancing the state of visual AI technology, which interests are not overridden by the rights and freedoms of data subjects given the anonymization measures applied; and (c) where applicable, consent provided by the User at the time of account creation or through subsequent affirmative action. For Users subject to the General Data Protection Regulation (GDPR) or similar data protection frameworks that require a specific legal basis for processing, Persephonie relies primarily on contractual necessity and legitimate interests for the processing described in this Section.

4.5 Retention of Processed Data

User Content that has been anonymized and incorporated into AI training datasets, model weights, benchmarking datasets, or research outputs may be retained indefinitely, as such processed data cannot practicably be extracted, isolated, or deleted from the models and systems into which it has been integrated. The original, non-anonymized User Content is retained in accordance with the data retention periods described in Section 6 of this Policy. USERS ACKNOWLEDGE AND AGREE THAT THE DELETION OF THEIR ACCOUNT OR USER CONTENT WILL NOT RESULT IN THE REMOVAL OF ANONYMIZED DATA THAT HAS ALREADY BEEN INCORPORATED INTO AI MODELS, TRAINING DATASETS, OR OTHER AGGREGATE DATA PRODUCTS.

5. How We Share Information

Persephonie does not sell your personal information. We may share, disclose, or otherwise make available your information to the following categories of recipients and for the following purposes:

5.1 Service Providers and Processors

We share information with third-party service providers, vendors, contractors, and processors who perform services on our behalf, including but not limited to: cloud infrastructure and hosting providers (for the storage and processing of data, including User Content and Tree Structures); payment processors (Stripe, for processing subscription payments and managing billing); AI and machine learning service providers (Anthropic, for processing User Content and generating decision tree outputs via the Claude API); analytics providers (for measuring Service usage, performance, and engagement); email and communication service providers (for delivering transactional and promotional communications); customer support tools and platforms; identity verification and fraud prevention services; content delivery networks; monitoring and logging services; and professional advisors (including legal, accounting, and consulting firms). These service providers are contractually bound to use your information only for the purposes for which it is disclosed to them, to maintain appropriate security measures, and to comply with applicable data protection laws. We require all service providers to enter into data processing agreements that include appropriate safeguards for the protection of personal data.

5.2 Business Transfers and Corporate Transactions

In the event of a merger, acquisition, reorganization, asset sale, bankruptcy, dissolution, or other corporate transaction or proceeding involving all or a portion of Persephonie's business or assets, your information may be among the assets transferred, disclosed, or otherwise made available to the acquiring entity, successor, or assignee. In such circumstances, we will use reasonable efforts to require that the recipient honor the terms of this Policy with respect to your personal information. We may also share information with potential acquirers, investors, and their advisors during the due diligence process preceding any such transaction, subject to appropriate confidentiality obligations.

5.3 Legal Compliance and Protection

We may disclose your information if we believe in good faith that such disclosure is necessary to: comply with applicable laws, regulations, legal processes, or governmental requests, including but not limited to subpoenas, court orders, search warrants, national security letters, and requests from regulatory authorities; enforce our Terms of Service, this Policy, or other agreements; investigate, prevent, or take action regarding suspected or actual illegal activity, fraud, security incidents, or threats to the safety of any person; protect the rights, property, or safety of Persephonie, our Users, or the public; and establish, exercise, or defend legal claims. Persephonie may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

5.4 Affiliates and Subsidiaries

We may share information with our current and future parent companies, subsidiaries, and affiliates for purposes consistent with this Policy, including for the provision of the Service, internal administration, data processing, analytics, service improvement, and other purposes described herein. All affiliates and subsidiaries that receive personal information are required to comply with the terms of this Policy or provide equivalent protections.

5.5 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified data that does not reasonably identify any individual with third parties for any purpose, including but not limited to: research and academic publications; industry benchmarking and analysis; marketing and promotional materials; business development and partnership discussions; and public reporting on trends in AI-assisted decision-making, visual AI output patterns, and decision tree usage statistics. Such aggregated data may include metrics on Tree Structure complexity, node exploration patterns, decision category distributions, and other statistical information derived from User interactions with the Service.

5.6 With Your Consent

We may share your information with third parties when you have provided your explicit consent for such sharing, including when you choose to share Tree Structures with other Users, publish decision trees publicly, integrate the Service with third-party applications, or participate in co-branded or joint offerings with our partners.

6. Data Retention

Persephonie retains your personal information for as long as necessary to fulfill the purposes for which it was collected, as described in this Policy, and in accordance with the following retention principles and timeframes:

6.1 Active Account Data

Account information, User Content, Tree Structures, conversation history, preferences, and other data associated with your account are retained for the duration of your account's existence and for a reasonable period thereafter to allow for account reactivation, dispute resolution, and compliance with legal obligations. Upon account deletion, we will initiate the deletion of your personal data within thirty (30) days, subject to the exceptions described below. Certain data may persist in encrypted backups for up to ninety (90) days following the initiation of deletion, after which backup copies will be overwritten through the normal backup rotation cycle.

6.2 Legal and Regulatory Retention

Notwithstanding the foregoing, we may retain personal information for longer periods as required or permitted by applicable laws, regulations, and legal obligations, including but not limited to: tax and accounting records (retained for up to seven (7) years or as required by applicable tax laws); transaction and billing records (retained for the period required by applicable financial regulations); records necessary to establish, exercise, or defend legal claims (retained for the applicable statute of limitations period plus a reasonable additional period); records required for regulatory compliance, audit, and reporting purposes; and records subject to litigation holds or preservation orders. In all cases, personal information retained for legal and regulatory purposes is stored securely and accessed only for the specific purposes for which retention is required.

6.3 Aggregated and Anonymized Data

Aggregated, anonymized, and de-identified data, including data derived from User Content and incorporated into AI training datasets, model parameters, benchmarking datasets, and research outputs, may be retained indefinitely. As described in Section 4.5, anonymized data that has been integrated into AI models and aggregate datasets cannot practicably be extracted or deleted. This data does not constitute personal information and is therefore not subject to data deletion requests or retention limitations applicable to personal data under this Policy or applicable law.

6.4 Log and Analytics Data

Server logs, access logs, and raw analytics data are retained for a maximum of twenty-four (24) months from the date of collection, after which they are either deleted or aggregated into anonymized datasets. Security-related logs, including authentication logs, access control logs, and incident response records, may be retained for up to thirty-six (36) months for security monitoring and forensic investigation purposes.

7. Data Security

Persephonie implements and maintains a comprehensive information security program designed to protect the confidentiality, integrity, and availability of your personal information and User Content. Our security measures include, without limitation:

Encryption. All data transmitted between your device and the Service is encrypted in transit using Transport Layer Security (TLS) 1.2 or higher. Sensitive data, including User Content, authentication credentials, and payment information, is encrypted at rest using AES-256 or equivalent encryption standards. Encryption keys are managed through industry-standard key management practices, including regular key rotation, separation of duties, and secure key storage.

Access Controls. Access to personal information and User Content is restricted to authorized personnel who require such access for the performance of their duties. We implement role-based access controls, multi-factor authentication for privileged accounts, least-privilege access principles, and regular access reviews and audits. All access to production systems and databases containing personal information is logged and monitored.

Infrastructure Security. The Service is hosted on secure cloud infrastructure with physical, network, and application-level security controls, including firewalls, intrusion detection and prevention systems, network segmentation, vulnerability scanning, penetration testing, and continuous monitoring. Our infrastructure providers maintain industry-recognized security certifications, including SOC 2 Type II and ISO 27001.

Incident Response. We maintain an incident response plan that provides for the prompt identification, containment, investigation, remediation, and notification of security incidents involving personal information. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected individuals and relevant supervisory authorities in accordance with applicable data breach notification laws and regulations.

NOTWITHSTANDING THE SECURITY MEASURES DESCRIBED HEREIN, NO METHOD OF TRANSMISSION OVER THE INTERNET, NO METHOD OF ELECTRONIC STORAGE, AND NO SECURITY SYSTEM IS COMPLETELY SECURE OR IMPENETRABLE. PERSEPHONIE CANNOT AND DOES NOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION, USER CONTENT, TREE STRUCTURES, OR ANY OTHER DATA TRANSMITTED TO, STORED BY, OR PROCESSED THROUGH THE SERVICE. YOU ACKNOWLEDGE AND ACCEPT THAT ANY TRANSMISSION OF INFORMATION TO THE SERVICE IS AT YOUR OWN RISK. IN THE EVENT OF A SECURITY BREACH, PERSEPHONIE'S LIABILITY SHALL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW AND THE TERMS OF SERVICE.

8. International Data Transfers

Persephonie, Inc. is headquartered in the United States of America. The Service is operated from, and data is primarily stored and processed in, the United States. If you access or use the Service from a location outside the United States, including from the European Economic Area, the United Kingdom, Switzerland, Canada, Australia, or any other jurisdiction, you understand and acknowledge that your personal information, User Content, Tree Structures, and other data will be transferred to, stored in, and processed in the United States and potentially other countries where our service providers maintain facilities.

The data protection laws of the United States and other countries to which your data may be transferred may differ from, and may not provide the same level of protection as, the laws of your country of residence. BY ACCESSING OR USING THE SERVICE, YOU EXPLICITLY CONSENT TO THE TRANSFER OF YOUR PERSONAL INFORMATION AND USER CONTENT TO THE UNITED STATES AND OTHER JURISDICTIONS AS DESCRIBED IN THIS POLICY. If you do not consent to such transfers, you must not use the Service.

For transfers of personal data from the EEA, UK, and Switzerland to the United States and other countries that have not received an adequacy determination from the European Commission or relevant authority, Persephonie relies on appropriate safeguards as required by applicable law, which may include: Standard Contractual Clauses (SCCs) adopted by the European Commission; the UK International Data Transfer Agreement or Addendum; supplementary measures including encryption and access controls; and any applicable data transfer frameworks or certifications. Users located in the EEA, UK, or Switzerland may request a copy of the applicable transfer mechanism by contacting us at the address provided in Section 16.

9. Your Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information. Persephonie is committed to facilitating the exercise of these rights in accordance with applicable data protection laws. The following rights may be available to you:

Right of Access. You have the right to request confirmation of whether Persephonie processes your personal information and, if so, to request access to that information, including the categories of personal data processed, the purposes of processing, the categories of recipients, the retention periods, and the source of the data. You may also request a copy of your personal data in a structured, commonly used, and machine-readable format.

Right to Correction. You have the right to request the correction or rectification of inaccurate or incomplete personal information that we hold about you. You may update certain account information directly through your account settings within the Service.

Right to Deletion. You have the right to request the deletion of your personal information, subject to certain exceptions. We may retain personal information as necessary to: comply with legal obligations; establish, exercise, or defend legal claims; complete pending transactions; maintain security and prevent fraud; and as otherwise permitted by applicable law. As described in Sections 4.5 and 6.3, anonymized data that has been incorporated into AI models, training datasets, and aggregate data products cannot be deleted.

Right to Restriction of Processing. You have the right to request that we restrict the processing of your personal information in certain circumstances, including: when you contest the accuracy of your personal data (for the period necessary to verify accuracy); when the processing is unlawful and you oppose deletion; when we no longer need the data but you require it for legal claims; and when you have objected to processing pending verification of our legitimate grounds.

Right to Data Portability. You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible and where the processing is based on consent or contractual necessity and carried out by automated means. This right applies to personal data you have provided to us and may include your account information, User Content, and Tree Structure data.

Right to Object. You have the right to object to the processing of your personal information based on our legitimate interests or for direct marketing purposes. Where you object to processing based on legitimate interests, we will cease processing unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

Right to Withdraw Consent. Where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent will not affect the provision of the Service to the extent that processing is based on other legal bases (such as contractual necessity or legitimate interests).

Right to Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe that our processing of your personal information violates applicable data protection laws.

To exercise any of the rights described above, please submit a verifiable request to us by contacting snow@houselumen.com. We will respond to verified requests within the timeframes required by applicable law (generally within thirty (30) days, with the possibility of extension where permitted). We may require you to verify your identity before processing your request to protect against unauthorized access to personal data. We will not discriminate against you for exercising your privacy rights.

10. California Privacy Rights (CCPA/CPRA)

This Section applies to California residents and supplements the information contained in the rest of this Policy with disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA").

10.1 Categories of Personal Information Collected

In the preceding twelve (12) months, we have collected the following categories of personal information as defined by the CCPA: (A) Identifiers, including name, email address, username, IP address, and unique device identifiers; (B) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including name, address, and financial information (payment card details processed by Stripe); (C) Protected classification characteristics, to the extent voluntarily provided by Users in User Content submitted for tree generation; (D) Commercial information, including subscription and transaction records, products or services purchased, and purchasing histories; (E) Internet or other similar network activity, including browsing history, search history, interactions with the Service, Tree Structure generation and exploration activity, and node click patterns; (F) Geolocation data, specifically approximate location derived from IP address; (G) Professional or employment-related information, for Enterprise account contacts; (H) Inferences drawn from the above categories to create profiles reflecting preferences, characteristics, behavior, and interactions with the Service; and (I) Sensitive personal information, limited to account login credentials (email and password) and, to the extent voluntarily included by Users in User Content, any personal information contained in questions and prompts submitted for decision tree generation.

10.2 Categories of Personal Information Disclosed

In the preceding twelve (12) months, we have disclosed the following categories of personal information for business purposes to the categories of service providers described in Section 5.1: Identifiers; Personal information categories (Cal. Civ. Code § 1798.80(e)); Commercial information; Internet or other similar network activity; Geolocation data; and Inferences. Personal information is disclosed to service providers solely for the business purposes described in this Policy, including providing the Service, processing payments, analytics, security, and customer support.

10.3 No Sale or Sharing of Personal Information

Persephonie does not sell personal information as defined by the CCPA. Persephonie does not share personal information for cross-context behavioral advertising purposes as defined by the CPRA. We have not sold or shared personal information in the preceding twelve (12) months. We do not have actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age.

10.4 California Consumer Rights

California residents have the following rights under the CCPA: the right to know what personal information is collected, used, disclosed, and sold; the right to request deletion of personal information; the right to correct inaccurate personal information; the right to opt out of the sale or sharing of personal information (Persephonie does not sell or share personal information); the right to limit the use of sensitive personal information to purposes necessary for providing the Service; and the right to non-discrimination for exercising CCPA rights. To exercise these rights, California residents may submit a verifiable consumer request by contacting snow@houselumen.com. We will verify your identity by matching information you provide with information we have on file. You may designate an authorized agent to submit requests on your behalf, subject to appropriate verification procedures.

11. EEA/UK/Swiss Privacy Rights (GDPR)

This Section provides additional information for individuals located in the European Economic Area ("EEA"), the United Kingdom ("UK"), and Switzerland, as required by the General Data Protection Regulation (EU) 2016/679 ("EU GDPR"), the UK General Data Protection Regulation ("UK GDPR"), and the Swiss Federal Act on Data Protection ("FADP") (collectively, "European Data Protection Laws").

11.1 Data Controller

Persephonie, Inc. is the data controller responsible for the processing of your personal data in connection with the Service. For questions about data processing or to exercise your rights, please contact us at snow@houselumen.com.

11.2 Legal Bases for Processing

We process your personal data on the following legal bases as applicable: (a) Performance of a Contract — processing necessary for the performance of our contract with you (the Terms of Service), including providing the Service, managing your account, processing transactions, generating Tree Structures, and providing customer support; (b) Legitimate Interests — processing necessary for our legitimate interests or those of a third party, where such interests are not overridden by your rights and freedoms, including analytics, service improvement, AI model training (for Free and Pro tiers, subject to anonymization), security, fraud prevention, and marketing; (c) Consent — processing based on your freely given, specific, informed, and unambiguous consent, including certain marketing communications and optional data sharing; and (d) Legal Obligation — processing necessary for compliance with legal obligations to which Persephonie is subject, including tax, accounting, and regulatory requirements.

11.3 Rights Under European Data Protection Laws

In addition to the rights described in Section 9, individuals subject to European Data Protection Laws have the following specific rights: the right to obtain information about the safeguards applied to international data transfers; the right to lodge a complaint with your local supervisory authority (for EEA residents, a list of supervisory authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en; for UK residents, the Information Commissioner's Office at https://ico.org.uk/); and the right to object to processing based on legitimate interests, including profiling, at any time. We will honor such objections unless we can demonstrate compelling legitimate grounds for the processing.

11.4 International Transfers from the EEA/UK/Switzerland

As described in Section 8, personal data transferred from the EEA, UK, or Switzerland to the United States is protected by appropriate safeguards, including Standard Contractual Clauses and supplementary technical and organizational measures. We conduct transfer impact assessments as required by applicable law and implement additional safeguards where necessary to ensure that transferred data receives an essentially equivalent level of protection.

12. Children's Privacy

The Service is not intended for, directed at, or designed to attract children under the age of thirteen (13) years, or under the age of sixteen (16) years for individuals located in the EEA or UK. Persephonie does not knowingly collect, solicit, or receive personal information from children under these age thresholds. We do not knowingly process User Content submitted by children for the generation of decision trees, Tree Structures, or other visual AI outputs.

If we become aware that we have collected personal information from a child under the applicable age threshold without verified parental or guardian consent, we will take prompt steps to delete such information from our records and terminate the associated account. If you believe that a child under the applicable age has provided us with personal information, or has used the Service to submit User Content for tree generation, please contact us immediately at snow@houselumen.com so that we can take appropriate action.

Parents and guardians who believe their child has provided personal information to Persephonie may exercise applicable data protection rights on behalf of their child by contacting us at the address provided in Section 16. We comply with the Children's Online Privacy Protection Act ("COPPA"), the Age Appropriate Design Code (UK), and other applicable laws and regulations regarding the protection of children's privacy.

13. Cookies and Tracking Technologies

Persephonie uses cookies and similar tracking technologies to collect information about your use of the Service, maintain your preferences, analyze Service performance, and improve your experience. This Section describes the types of cookies and tracking technologies we use and the purposes for which they are employed.

13.1 Types of Cookies

Strictly Necessary Cookies. These cookies are essential for the operation of the Service and cannot be disabled. They include cookies that maintain your authenticated session, store your theme preference (light, dark, or system), remember your consent choices, enable security features such as CSRF protection, and manage load balancing across our infrastructure. Without these cookies, the Service cannot function properly.

Performance and Analytics Cookies. These cookies collect information about how you use the Service, including which pages and features you access, how long you spend on different sections, which Tree Structures you generate and interact with, error messages received, and other usage metrics. This information is used to analyze and improve the performance, reliability, and user experience of the Service. Analytics data may be processed by third-party analytics providers as described in Section 14.

Functionality Cookies. These cookies enable enhanced functionality and personalization, including remembering your preferences, settings, and customizations; storing recently viewed Tree Structures for quick access; and enabling features that rely on recognizing returning users. If you disable functionality cookies, certain features of the Service may not work as intended.

13.2 Other Tracking Technologies

In addition to cookies, we may use other tracking technologies including: web beacons (also known as pixel tags or clear GIFs), which are small graphic images embedded in web pages or emails that allow us to determine whether specific actions have been taken; local storage objects (including HTML5 localStorage and sessionStorage), which allow us to store data locally on your device for performance and functionality purposes, including storing your Zustand state, theme preferences, and cached Tree Structure data; and software development kits (SDKs) in any mobile or desktop applications we may offer in the future.

13.3 Cookie Management

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, and you can typically find these settings in the "Options," "Preferences," or "Settings" menu of your browser. Please note that blocking or deleting cookies may affect the functionality of the Service, and certain features (including authentication, theme persistence, and Tree Structure caching) may not work properly if cookies are disabled. For more information about cookies and how to manage them, visit www.allaboutcookies.org.

13.4 Do Not Track Signals

Some browsers offer a "Do Not Track" ("DNT") signal that indicates a preference not to be tracked by websites. There is currently no universally accepted standard for how companies should respond to DNT signals. At this time, Persephonie does not respond to DNT signals or similar mechanisms. If a uniform standard for responding to DNT signals is established, we will review and update this Policy accordingly. Notwithstanding the foregoing, you may exercise your privacy rights as described in Section 9 of this Policy regardless of any DNT signal setting.

14. Third-Party Analytics

We use third-party analytics services to help us understand how Users interact with the Service, measure the effectiveness of features, diagnose performance issues, and generate aggregated usage reports. These analytics providers may collect information about your use of the Service through cookies, web beacons, SDKs, and similar technologies, and may combine this information with data collected from other websites, applications, and online services.

Analytics providers we may use include, without limitation: Vercel Analytics and Vercel Web Analytics (for performance monitoring, page view tracking, and web vitals measurement); PostHog (for product analytics, session recording, and feature flag evaluation); Mixpanel (for event tracking, funnel analysis, and user journey mapping); and other analytics tools that we may integrate into the Service from time to time. Each analytics provider processes data in accordance with its own privacy policy and terms of service. We encourage you to review the privacy policies of these providers to understand their data practices.

We use analytics data to understand usage patterns across the Service, including: which types of questions generate the most complex Tree Structures; how Users navigate and explore decision tree branches and nodes; which features are most frequently used; where Users encounter errors or abandon sessions; how different visualization layouts affect engagement and comprehension; and how Service performance varies across devices, browsers, and geographic regions. This analysis enables us to make informed decisions about product development, feature prioritization, and infrastructure optimization.

15. Changes to This Privacy Policy

Persephonie reserves the right to modify, amend, or update this Policy at any time and for any reason, in our sole discretion. When we make changes to this Policy, we will update the "Last updated" date at the top of this page. For material changes that significantly affect the way we collect, use, or share your personal information, we will provide notice through one or more of the following methods: posting a prominent notice on the Service; sending an email notification to the email address associated with your account; displaying an in-app notification or banner; or, where required by applicable law, obtaining your consent prior to implementing the changes.

Your continued use of the Service after the effective date of any changes to this Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must discontinue your use of the Service and, if applicable, delete your account. We encourage you to review this Policy periodically to stay informed about our data practices. Material changes will not be applied retroactively to personal information collected prior to the change without your consent, except where permitted or required by applicable law.

For significant changes to the terms governing the use of User Content for service improvement purposes (Section 4), Persephonie will provide at least thirty (30) days' advance notice before such changes take effect, except where immediate changes are required by law, regulation, or court order.

16. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, our data practices, or your privacy rights, please contact us at:

Persephonie, Inc.
Attn: Privacy Team
Email: snow@houselumen.com

For data protection inquiries from individuals located in the EEA, UK, or Switzerland, you may also contact our designated privacy representative at the email address above. We will make every effort to respond to your inquiry within thirty (30) days or such shorter period as may be required by applicable law.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the appropriate data protection supervisory authority in your jurisdiction. For EEA residents, a list of supervisory authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. For UK residents, you may contact the Information Commissioner's Office at https://ico.org.uk/. For Swiss residents, you may contact the Federal Data Protection and Information Commissioner (FDPIC).