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    Vigilum Privacy Policy

    Effective Date: [01, 2026]

    Last Updated: [04, 2026]

    1. Who We Are (Controller)

    This Privacy Policy explains how SIA Vigilum (“Vigilum”, “we”, “us”, “our”) collects and uses personal information when you visit vigilum.ai or contact us through our website.

    Controller (GDPR):
    SIA Vigilum (Latvia)
    Registered address: Vienības prospekts 43, Jūrmala, LV-2010, Latvia

    Contact (privacy):
    Email: [privacy@vigilum.ai]
    Postal: SIA Vigilum, Vienības prospekts 43, Jūrmala, LV-2010, Latvia

    If you do not agree with this Privacy Policy, please do not use the Services.

    2. Scope

    This Privacy Policy applies to:

    • visitors to vigilum.ai, and
    • individuals who submit inquiries (e.g., partnership, collaboration, demo requests) via our website.

    This Privacy Policy does not cover:

    • third‑party websites linked from our site, or
    • customer deployments of Vigilum/Clavis that are governed by separate agreements (e.g., a Data Processing Agreement) where applicable.

    3. What Personal Information We Collect

    3.1 Information you provide

    When you submit a form or contact us, we may collect:

    • Identity and contact details: name, business email, (optional) phone number, country
    • Professional details: organization/company, job title/role
    • Inquiry content: any information you include in your message (e.g., goals, context, requirements)
    • Preference/consent records: records of your communication preferences and cookie choices (where applicable)

    Important: Please do not submit sensitive personal data (special category data under GDPR Art. 9) through our marketing site forms.

    3.2 Information collected automatically (website use)

    When you browse vigilum.ai, we may collect:

    • Device and usage data: IP address, browser type/version, device type, operating system, pages viewed, referring page, approximate timestamps, and similar usage data
    • Cookie and tracking data: as described in Section 9

    3.3 Information from third parties

    For the marketing site inquiry flow, we do not intentionally collect personal information about you from third‑party sources (such as public databases or data brokers).

    4. How We Use Personal Information

    We use personal information to:

    4.1 Respond to inquiries and communicate

    • respond to messages and requests
    • schedule discussions, demos, or pilot conversations
    • manage ongoing communications you initiate

    4.2 Operate, secure, and maintain the website

    • provide the website and prevent abuse
    • detect and mitigate security incidents and fraud
    • maintain logs needed for reliability and security

    4.3 Measure and improve the website (analytics)

    • understand how visitors use the website
    • improve content, usability, and performance

    5. Legal Bases for Processing (GDPR Art. 6)

    We rely on the following legal bases:

    Consent (Art. 6(1)(a))
    For non-essential cookies/analytics where required (e.g., Google Analytics), based on your cookie banner choices.

    Legitimate interests (Art. 6(1)(f))
    To respond to business inquiries, operate and secure our website, and improve it—balanced against your rights and expectations. Our legitimate interests include: operating our business communications, maintaining website security, and improving our site.

    Steps to enter a contract (Art. 6(1)(b))
    Where your inquiry relates to evaluating or preparing a potential engagement.

    Legal obligation (Art. 6(1)(c))
    Where we must retain certain records to comply with applicable law.

    6. Summary Table: Purposes, Data, and Retention

    PurposeData categoriesLegal basisTypical retention
    Respond to inquiries / manage communicationsname, email, org, message contentLegitimate interests or Art. 6(1)(b)24 months from last contact
    Website analytics (Google Analytics)online identifiers, device/usage eventsConsent[your GA retention period] (commonly 2–14 months)
    Security and abuse preventionIP, request metadata, security logsLegitimate interests[30–90 days] (typical)
    Legal/complianceminimal necessary recordsLegal obligationup to 5 years (or as required)

    We may retain data longer if necessary to establish, exercise, or defend legal claims.

    7. Sharing and Disclosure

    We do not sell personal information.

    We may share personal information with:

    7.1 Service providers (processors)

    Vendors that help us operate the website and communications (e.g., hosting, email, analytics, security). They may process personal information only on our instructions and under contractual confidentiality and data protection obligations.

    7.2 Legal and safety disclosures

    We may disclose information where required by law or where we believe disclosure is necessary to:

    • comply with legal process,
    • protect rights, safety, and security of Vigilum and others,
    • prevent fraud or abuse.

    7.3 Business transfers

    If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to appropriate protections.

    8. International Transfers

    We are based in Latvia (EU). Some service providers (including analytics providers) may process data outside the EEA.

    Where personal information is transferred outside the EEA, we use appropriate safeguards such as:

    • Standard Contractual Clauses (SCCs), and/or
    • adequacy decisions where applicable.

    9. Cookies and Tracking (Including Google Analytics)

    9.1 Cookie types

    We use:

    • Essential cookies (necessary for core site functionality and security)
    • Analytics cookies (to understand usage and improve the website)

    9.2 Consent and choices

    Where required, analytics cookies are set only if you consent via our cookie banner. Builder-hosted images and media are also deferred until you grant analytics consent, so those third-party requests are not made before consent.

    You can withdraw or change your cookie consent at any time by:

    • using our cookie settings link: [Cookie Settings URL], and/or
    • adjusting your browser settings.

    9.3 Google Analytics

    We use Google Analytics to measure website usage and improve content and performance. Google may process online identifiers and usage data. Depending on configuration and network routing, data may be processed outside the EEA with safeguards as described in Section 8.

    (If you have specific GA settings you want stated—IP anonymization, ad features disabled, etc.—tell me and I’ll encode them precisely.)

    10. Your Rights (GDPR)

    Subject to applicable law, you may have the right to:

    • access your personal information
    • correct inaccurate information
    • delete your personal information
    • restrict processing
    • object to processing based on legitimate interests
    • withdraw consent (where processing is based on consent)
    • receive a copy of certain data (data portability)

    To exercise rights, contact us at [privacy@vigilum.ai].

    Complaints
    You also have the right to lodge a complaint with the Latvian supervisory authority:
    Latvian Data State Inspectorate (DVI)
    Elijas iela 17, Rīga, LV-1050, Latvia
    Website: https://www.dvi.gov.lv

    11. Security

    We maintain appropriate technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

    (If you want, we can add a short “Security Practices” subsection that states only what you can prove today.)

    12. Children

    The Services are not directed to children under 16, and we do not knowingly collect personal information from children under 16.

    13. AI and Automated Decision-Making

    Our marketing website inquiry flow does not involve solely automated decision-making that produces legal or similarly significant effects.

    We do not use marketing-site inquiry personal information to train AI models.

    14. Third‑Party Links

    Our website may link to third‑party sites. We are not responsible for their privacy practices. Please review their policies.

    15. Changes to This Policy

    We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Last Updated” date.

    16. Contact

    Questions or requests:

    Email: [privacy@vigilum.ai]
    Postal: SIA Vigilum, Vienības prospekts 43-18, Jūrmala, LV-2010, Latvia