Privacy Policy

1. Data controller

Verbum 11 is currently a personal project operated from Romania. The individual operating the project is the controller of account and service data. Privacy requests can be sent to 21bluesupport@gmail.com.

2. Data we process

• Account data: email address, authentication identifiers, and login session data.
• User content: uploaded PDFs and spreadsheets, extracted product information, niche scores, notes, settings, and saved analyses.
• Technical and security data: IP address, device/browser information, timestamps, and diagnostic logs generated by hosting and security providers.
• AI request data: uploaded documents and relevant niche data sent to OpenAI to provide the AI features you request.

3. Purposes and legal bases

• Provide accounts, uploads, scoring, storage, and AI analysis: performance of the service contract.
• Keep the service secure, prevent abuse, troubleshoot failures, and defend legal claims: legitimate interests.
• Meet tax, accounting, consumer, or legal obligations where applicable: legal obligation.
• Optional analytics or marketing, if introduced later: consent obtained before those technologies are activated.

4. Service providers and international transfers

We use Supabase for authentication and database services, Vercel for hosting, and OpenAI for AI document and web analysis. These providers process data on our behalf under their terms and data-processing arrangements. Depending on account and infrastructure configuration, data may be processed outside the European Economic Area using an applicable transfer mechanism such as an adequacy decision or Standard Contractual Clauses.

5. Retention

Account content is retained while your account is active and until you delete it, subject to backups and legal obligations. PDFs sent for analysis are deleted from OpenAI through the API after processing; diagnostic or abuse-monitoring records may be retained by providers under their published policies. Security logs are kept only as long as reasonably necessary for security and troubleshooting.

6. Your choices and rights

You can export research, delete uploads, and delete your account from the service. GDPR rights, request procedures, response times, and complaint information are explained on the GDPR Rights page.

7. Automated analysis

AI extracts and summarizes research, while niche scores use visible rules and user-configurable thresholds. Verbum 11 does not make legal or similarly significant decisions about individuals. AI output may be incomplete or inaccurate and must be reviewed by the user.

8. Security and children

We use access controls, encrypted transport, account-level database policies, and data minimisation. No online system is completely risk-free. The service is intended for adults and is not directed to children under 16.

9. Changes and contact

Material changes will be reflected by updating the date above and, when appropriate, notifying account holders. Contact 21bluesupport@gmail.com with privacy questions.