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.

4. Service providers and international transfers

We use the following providers to operate this personal testing service:

• Supabase, for authentication, database, and storage services, hosted in West EU (Ireland).
• Vercel, for application hosting and delivery, with Functions configured for Dublin, Ireland (West), subject to deployment taking effect.
• OpenAI, for the AI document, research, and writing-support features you request.

These providers process data under their own applicable terms and data-processing arrangements. OpenAI processing and its infrastructure may involve transfers outside the European Economic Area. Before any commercial launch, we will publish the then-current processor, hosting-region, and international-transfer information. Where data is processed outside the European Economic Area, an applicable transfer mechanism, such as an adequacy decision or Standard Contractual Clauses, may apply.

5. Retention

Account content is retained while your account is active and until you delete it, subject to backups and legal obligations. Documents and prompts sent to OpenAI are handled through the API and remain subject to the applicable API retention and deletion controls. Diagnostic or abuse-monitoring records may be retained by providers under their published policies. Security and rate-limit records are pseudonymous and retained only for the short period needed to protect the service and troubleshoot abuse.

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 and OpenAI

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. If you publish, submit, or otherwise use AI-assisted output publicly, you are responsible for checking it and for any disclosure or labelling required by the rules that apply to you.

OpenAI's API data controls state that API inputs and outputs are not used to train OpenAI models by default unless the account owner opts in. This statement does not replace OpenAI's current terms, data controls, or retention practices, which may apply to a specific request.

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. Security incidents

If we become aware of a personal-data security incident, we will assess it, take reasonable steps to contain and investigate it, and make notifications to the competent authority or affected individuals when required by applicable law. Timing and the content of any notice depend on the facts of the incident and legal requirements.

10. 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.