Privacy Policy

Last updated: December 2024

1. Information We Collect

We collect information in several ways: **Personal Information You Provide:** • Full name and professional title • Business email address • Phone number • Company name and industry • Job function and department • Project requirements and business challenges • Any other information you choose to provide in forms or communications **Automatically Collected Information:** • IP address and geographic location • Browser type and version • Operating system • Device information • Pages visited and time spent • Referring website • Click patterns and navigation paths • Cookies and similar tracking technologies

2. How We Use Your Information

We use the collected information for the following purposes: • **Service Delivery:** To respond to your inquiries, provide consultations, and deliver our AI and data science services • **Communication:** To send you relevant information about our services, including updates, newsletters, and marketing materials (with your consent) • **Personalization:** To customize your experience and provide tailored recommendations • **Analytics:** To analyze usage patterns, improve our website, and enhance our services • **Legal Compliance:** To comply with applicable laws, regulations, and legal processes • **Business Operations:** To manage our business, including billing, customer support, and internal reporting • **Security:** To detect, prevent, and respond to fraud, security threats, or technical issues

3. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), we process personal data based on: • **Consent:** When you have given explicit consent for specific purposes • **Contract Performance:** When processing is necessary to fulfill our contractual obligations • **Legitimate Interests:** For our legitimate business interests, such as improving services and marketing • **Legal Obligations:** When required to comply with applicable laws

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share information with: • **VEX Holding Entities:** With our parent company and affiliated entities for operational purposes • **Service Providers:** With trusted third-party vendors who assist in our operations (cloud hosting, analytics, CRM) • **Legal Requirements:** When required by law, court order, or governmental authority • **Business Transfers:** In connection with a merger, acquisition, or sale of assets • **With Your Consent:** When you have explicitly authorized disclosure All third-party providers are contractually obligated to protect your data and use it only for specified purposes.

5. Data Security

We implement robust security measures to protect your information: • **Encryption:** SSL/TLS encryption for data in transit; AES-256 encryption for data at rest • **Access Controls:** Role-based access controls and multi-factor authentication • **Infrastructure:** Enterprise-grade cloud infrastructure (AWS, Azure, Google Cloud) with SOC 2 compliance • **Monitoring:** 24/7 security monitoring and intrusion detection • **Training:** Regular security training for all employees • **Audits:** Periodic security assessments and penetration testing While we strive to protect your information, no method of transmission or storage is 100% secure. We encourage you to use strong passwords and protect your account credentials.

6. Your Rights and Choices

Depending on your location, you may have the following rights: • **Access:** Request a copy of your personal data • **Rectification:** Correct inaccurate or incomplete data • **Erasure:** Request deletion of your personal data ("Right to be Forgotten") • **Portability:** Receive your data in a structured, machine-readable format • **Restriction:** Limit how we process your data • **Objection:** Object to processing based on legitimate interests • **Withdraw Consent:** Revoke previously given consent • **Opt-Out:** Unsubscribe from marketing communications To exercise these rights, contact us at business@vexholding.com. We will respond within 30 days.

7. International Data Transfers

Your data may be processed in: • **United States:** Our headquarters in Sheridan, Wyoming • **Brazil:** Our development hub in São Paulo • **India:** Our engineering center • **European Union:** For EU-based clients For transfers outside your jurisdiction, we implement appropriate safeguards including Standard Contractual Clauses (SCCs), Privacy Shield certifications where applicable, and binding corporate rules.

8. Cookies and Tracking Technologies

We use cookies and similar technologies for: • **Essential Cookies:** Required for website functionality • **Analytics Cookies:** To understand how visitors interact with our site (Google Analytics) • **Marketing Cookies:** To deliver relevant advertisements and measure campaign effectiveness You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect website functionality.

9. Data Retention

We retain personal data for as long as necessary to: • Fulfill the purposes for which it was collected • Comply with legal obligations • Resolve disputes and enforce agreements Typically, we retain client data for 7 years after the end of the business relationship for legal and tax purposes. Marketing data is retained until you unsubscribe or request deletion.

10. LGPD Compliance (Brazil)

For Brazilian residents under Lei Geral de Proteção de Dados (LGPD): • **Data Controller:** VEX Holding LLC • **DPO Contact:** business@vexholding.com • **Rights:** Access, correction, anonymization, portability, deletion, consent revocation • **Legal Bases:** Consent, contract performance, legitimate interests, legal obligations We are committed to full LGPD compliance and work with certified data protection professionals.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated "Last Updated" date. For significant changes, we will provide prominent notice or direct notification. We encourage you to review this policy regularly.

13. Contact Us

For questions, concerns, or to exercise your rights: **VEX AI-Tech (Division of VEX Holding LLC)** Email: business@vexholding.com Headquarters: Sheridan, Wyoming, USA We aim to respond to all inquiries within 48 business hours.