PRIVACY POLICY¶

Last Updated: 01 Aug 2025

Company information, standard definitions, regulatory compliance framework, and document integration: See Shared Legal Definitions and Legal Framework Integration

1. INTRODUCTION¶

1.1 Scope and Purpose¶

This Privacy Policy ("Policy") describes how Innovatica Technologies FZ-LLC collects, uses, processes, shares, retains, and protects personal data and non-personal information when you access or use our Brilio platform. This Policy has been designed to achieve global legal defensibility across all jurisdictions where we operate.

1.2 Service Coverage¶

This Policy applies to all users of the Brilio platform, including individuals who create an account, create or use AI agents, or otherwise interact with our Services. It covers information collected through: - The Brilio website (brilio.ai) - The Brilio platform and all associated services - Communications between you and Innovatica regarding the Service - Any mobile applications or API integrations we may offer - Third-party integrations and connected services

1.3 User Acknowledgment¶

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein, subject to your rights under applicable law.

2. DATA CONTROLLER AND PROCESSOR ROLES¶

2.1 Data Controller Responsibilities¶

Innovatica Technologies FZ-LLC is the data controller for personal information processed in connection with our Services. For users who create and deploy AI agents on our platform, Innovatica acts as a data processor with respect to information processed by those agents on behalf of the agent creator, who acts as the data controller for such processing activities.

2.2 Contact Information¶

Data Controller Contact Information: - Company: Innovatica Technologies FZ-LLC - Address: VUNE0632, Compass Building - Al Hulaila, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates - Email: privacy@innovatica.ai

Data Protection Officer: - Email: dpo@innovatica.ai - Responsible for: Privacy compliance, data subject requests, and regulatory correspondence

3. CATEGORIES OF DATA WE COLLECT¶

3.1 Account Information¶

Email address
Full name
Password (stored in hashed format)
Billing information and payment details (processed through our payment provider)
Account preferences and settings
Profile information you choose to provide

3.2 Usage Data¶

Log data (IP address, browser type, referring/exit pages, operating system)
Device information (device type, operating system, unique device identifiers)
Usage metrics (features used, interactions with agents, session duration)
Location data (region and country, derived from IP address)
Telemetry data for platform performance monitoring
Subscription information and credit usage

Content provided to create and train agents
Names, descriptions, and configuration of agents
Knowledge bases and data sources connected to agents
Agent interactions and usage statistics
Content generated by agents

3.4 Communications Data¶

Customer support inquiries and related communications
Responses to surveys or feedback requests
Marketing preferences and interactions with marketing communications

3.5 Platform-Generated Data¶

Automatically generated IDs and technical identifiers
Timestamps and audit logs
Technical error reports and debugging information
Performance metrics and analytics

4. HOW WE USE YOUR DATA¶

4.1 Service Provision¶

Creating and managing your account
Providing platform features and functionality
Processing payments and managing subscriptions
Delivering customer support

4.2 Platform Operation¶

Monitoring platform performance and security
Detecting and preventing fraud, abuse, and security threats
Troubleshooting technical issues
Maintaining data integrity and backup systems

4.3 Improvement and Development¶

Analyzing usage patterns to improve platform features
Developing new products and services
Conducting research and development
Training and improving AI models (with appropriate safeguards)

4.4 Legal and Compliance¶

Complying with legal obligations and regulatory requirements
Protecting our rights and interests
Responding to law enforcement requests
Enforcing our terms of service

4.5 Communication¶

Sending service-related communications
Providing customer support
Delivering marketing communications (with proper consent)
Notifying you of policy changes or security issues

5. LEGAL BASIS FOR PROCESSING¶

5.1 Contractual Necessity¶

We process personal data as necessary to perform our contract with you, including account management, service delivery, and payment processing.

5.2 Legitimate Interests¶

We process data based on legitimate interests including platform security, fraud prevention, service improvement, and business operations.

5.3 Legal Obligations¶

We process data to comply with applicable laws, regulations, and legal proceedings.

For certain processing activities, we rely on your explicit consent, which you may withdraw at any time.

6.1 Service Providers¶

We share data with trusted third-party service providers who help us operate the platform, including: - Cloud hosting providers (Microsoft Azure) - Payment processors (Stripe) - AI model providers (OpenAI, Anthropic) - Analytics and monitoring services - Customer support tools

6.2 Business Transfers¶

In connection with any merger, acquisition, or sale of assets, user data may be transferred as part of the transaction.

6.3 Legal Requirements¶

We may disclose data when required by law, regulation, legal process, or governmental request.

6.4 Protection of Rights¶

We may disclose data to protect our rights, property, safety, or that of our users or others.

We may share data for other purposes with your explicit consent.

7. DATA RETENTION AND DELETION¶

7.1 Retention Principles¶

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law.

7.2 Account Data Retention¶

Active accounts: Data retained while account is active
Deleted accounts: 90-day soft delete period, then permanent deletion
Billing data: Retained for tax and regulatory compliance (typically 7 years)
Support communications: Retained for 3 years for service improvement

7.3 Usage and Analytics Data¶

Raw usage logs: 2 years
Aggregated analytics: 5 years (anonymized)
Security logs: 1 year (unless incident-related)

7.4 Agent and Content Data¶

Agent configurations: Retained until account deletion
User-uploaded content: Retained according to user preferences
AI-generated content: Subject to user control and deletion requests

7.5 User-Requested Deletion¶

Users may request data deletion through account settings or by contacting our Data Protection Officer. We will process deletion requests within 30 days, subject to legal retention requirements.

8. DATA SECURITY¶

8.1 Technical Safeguards¶

Encryption of data in transit (TLS 1.3) and at rest (AES-256)
Multi-factor authentication for administrative access
Regular security assessments and penetration testing
Automated threat detection and response systems

8.2 Organizational Measures¶

Employee training on data protection and privacy
Access controls and need-to-know principles
Regular security policy reviews and updates
Incident response and breach notification procedures

8.3 Third-Party Security¶

All service providers are required to maintain appropriate security measures and undergo regular security assessments.

9. INTERNATIONAL DATA TRANSFERS¶

9.1 Global Operations¶

Data may be transferred to and processed in countries where we or our service providers operate, including the United States, European Union, and Asia-Pacific regions.

9.2 Transfer Safeguards¶

For transfers outside your jurisdiction, we implement appropriate safeguards including: - Standard Contractual Clauses (SCCs) - Adequacy decisions by relevant authorities - Binding Corporate Rules where applicable - Additional security measures as required

9.3 Data Sovereignty Options¶

Enterprise customers may request data residency in specific regions subject to technical and commercial feasibility.

10. YOUR PRIVACY RIGHTS¶

10.1 Universal Rights¶

Regardless of location, you have the right to: - Access your personal data - Correct inaccurate information - Request data deletion (subject to legal requirements) - Object to certain processing activities - Withdraw consent where applicable

If you are in a jurisdiction with enhanced privacy laws, you may also have rights to: - Data portability - Restriction of processing - Automated decision-making opt-out - Detailed information about data processing

10.3 Exercising Your Rights¶

To exercise your privacy rights, contact us at privacy@innovatica.ai or use the privacy controls in your account settings. We will respond to requests within 30 days (or as required by applicable law).

11. COOKIES AND TRACKING TECHNOLOGIES¶

11.1 Types of Cookies¶

We use the following categories of cookies:

Essential Cookies - Required for basic platform functionality - Authentication and session management - Security and fraud prevention

Functional Cookies - Remember user preferences and settings - Provide enhanced features and personalization - Support multi-language functionality

Analytics Cookies - Understand how users interact with the platform - Measure platform performance and usage - Identify areas for improvement

Marketing Cookies (with consent) - Deliver relevant advertising - Measure marketing campaign effectiveness - Personalize marketing communications

You can control cookies through: - Browser settings and preferences - Platform cookie consent tools - Third-party opt-out mechanisms

Disabling certain cookies may limit platform functionality and user experience.

12. CHILDREN'S PRIVACY¶

12.1 Age Restrictions¶

The Brilio platform is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.

12.2 Parental Rights¶

If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

13. CHANGES TO THIS POLICY¶

13.1 Policy Updates¶

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.

13.2 Notification of Changes¶

We will notify users of material changes through: - Email notifications to registered users - Prominent notices on our website - In-platform notifications

13.3 Continued Use¶

Continued use of the platform after policy changes constitutes acceptance of the updated policy.

14. CONTACT INFORMATION¶

For questions about this Privacy Policy or our privacy practices, contact us at:

Email: privacy@innovatica.ai
Data Protection Officer: dpo@innovatica.ai
Address: VUNE0632, Compass Building - Al Hulaila, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates

This Privacy Policy consolidates data protection terms from multiple documents to provide comprehensive coverage while maintaining regulatory compliance across all jurisdictions.