AI-Intelligence Privacy Policy

PRIVACY NOTICE

Last updated: 2 September 2026

1. Who We Are

1.1 The controller of your personal data is:

SINGULARITY.INC FlexCo (Flexible Kapitalgesellschaft)Schwemmweg 46, 2100 Leobendorf, AustriaFirmenbuch: FN 656179 w, Landesgericht Korneuburg

1.2 Data protection contact: Dr. Christian Öhner, christian@aiintelligence.inc, +43 664 326 1616.

1.3 We have not appointed a Data Protection Officer because the criteria of Article 37 GDPR are not met. You may direct any data-protection inquiry to the contact above.

1.4 Our competent supervisory authority is the Österreichische Datenschutzbehörde, Barichgasse 40–42, 1030 Wien, dsb@dsb.gv.at, www.dsb.gv.at.

2. What This Notice Covers

2.1 This notice describes how we process personal data in connection with the AI-Intelligence platform, including:

(a) the AI-Intelligence web community at aiintelligence.inc;

(b) the branded AI-Intelligence iOS and Android app;

(d) the marketing pages at aiintelligence.inc;

(e) checkout, billing and support communications.

2.2 This notice does not cover processing by AIVY (aivy.singularity.inc), which is governed by its own combined User Agreement and Privacy Information, or by airis, which is governed by its own EULA. Where you use AIVY through the AI-Intelligence platform, the AIVY privacy terms apply to that interaction.

2.3 This notice stands on its own. You do not need to read any other privacy document to understand how we handle your data on the AI-Intelligence platform.

3. What Personal Data We Process and Why

The following table sets out the categories of personal data we process, the purposes, and the legal basis for each.

Category

Data

Purpose

Legal Basis

Account and identity

Name, email, password hash, OTP, profile photo, bio, links, content-track tag

Account creation and management; tier access; authentication

Art 6(1)(b) — contract performance

Community content

Posts, comments, reactions, direct messages, uploaded media

Operating the community forum; enabling member interaction

Art 6(1)(b) — contract performance

Course data

Lesson progress, completion status, self-scored quiz responses

Enabling you to track your own progress; course completion statistics (no individual evaluation or grading)

Art 6(1)(b) — contract performance

Live sessions

Attendance, camera/mic contributions (voluntary), session chat, recordings, machine transcripts

Delivering live programme content; providing catch-up access to enrolled participants

Art 6(1)(f) — legitimate interest (providing the service; recordings enable catch-up)

Billing and payment

Payment token, billing address, VAT/UID, invoices, Stripe Tax data

Processing payments; issuing invoices; tax compliance

Art 6(1)(b) — contract; Art 6(1)(c) — legal obligation (§132 BAO)

Certification cohort

Enrolment data, attendance, proof case submission, credential register entry

Administering the cohort; assessing completion; maintaining verifiable credential register

Art 6(1)(b) — contract; Art 6(1)(f) — legitimate interest (credential integrity)

Communications

Notification/digest emails, delivery/engagement data, support correspondence

Platform notifications; service communications; responding to support inquiries

Art 6(1)(b) — contract; Art 6(1)(f) — legitimate interest (service improvement)

Technical data

IP address, device/browser info, app version, push tokens, session IDs

Platform security; abuse prevention; technical troubleshooting

Art 6(1)(f) — legitimate interest (security and platform stability)

Launch waitlist

Email address, name (optional), preferred language, consent record and timestamp

Sending you a single notification on the day the platform opens to the public

Art 6(1)(a) — consent, withdrawable at any time

Marketing

Email address, consent record, engagement data

Sending marketing communications about AI-Intelligence services

Art 6(1)(a) — consent (non-members); Art 6(1)(f) — legitimate interest (existing members, similar services, §174 Abs 4 TKG)

Special categories

Only if voluntarily disclosed by you in community content

Hosting content you choose to share

Art 9(2)(a) — explicit consent (manifested by the act of voluntary posting)

4. Cookies and Tracking Technologies

4.1 The AI-Intelligence platform uses cookies and similar technologies deployed by Circle (our platform host) to enable core functionality (authentication, session management, preferences) and to collect usage analytics.

4.2 Strictly necessary cookies (those required for the platform to function, including authentication and security) are placed on the legal basis of Article 6(1)(b) GDPR (necessary for contract performance) and do not require your consent.

4.3 Analytics and non-essential cookies require your prior consent, which we collect through the consent mechanism presented on your first visit. You may withdraw consent or change your preferences at any time through the cookie settings accessible from the platform footer.

4.4 The Company does not deploy its own tracking technologies independently of the Circle platform. The cookies set on the AI-Intelligence domain are Circle-operated. A current inventory of cookies, their purposes, and retention periods is maintained in the cookie consent tool and updated as Circle communicates changes to us.

4.5 The legal framework applicable to cookies and similar technologies is §165 TKG 2021 (Telekommunikationsgesetz), implementing Article 5(3) of Directive 2002/58/EC (ePrivacy Directive).

4.6 We do not engage in cross-site tracking, sell tracking data, or permit third-party advertising cookies on the platform.

5. Who Receives Your Data

5.1 We share your personal data with the following categories of recipients, solely for the purposes described in this notice:

(a) Circle Media Inc. (San Francisco, United States) — platform hosting, course video delivery, community features, notification emails, live rooms, machine transcription. Circle acts as our processor under a data processing agreement.

(b) Stripe, Inc. (San Francisco, United States) — payment processing, billing, invoicing, tax calculation (Stripe Tax). Stripe acts as our processor for payment handling.

(c) Apple Inc. / Google LLC — app distribution via App Store and Google Play; push notification delivery. These companies act as independent controllers for their own app-store processing and as processors for push notification routing.

(d) Google Workspace (Google Ireland Limited) — support correspondence mailbox. Google acts as processo

(e) Airtable, Inc. (San Francisco, United States) — hosting of the pre-launch waitlist form and the resulting contact list until the platform opens to the public. Airtable acts as our processor under a data processing agreement.r.

5.2 We do not sell your personal data. We do not share your data with third parties for their own marketing or commercial purposes. We do not provide your data to data brokers.

5.3 We may disclose personal data where required by law, regulation, court order, or binding order of a competent authority.

6. International Transfers

6.1 Your personal data is transferred to the United States in connection with the services provided by Circle, Stripe and (for push notifications) Apple/Google. Until the platform opens to the public, waitlist data is also transferred to the United States in connection with the waitlist form and contact list hosted by Airtable, Inc.

6.2 These transfers are protected by the following safeguards:

(a) EU-US Data Privacy Framework (DPF): Where the recipient is certified under the DPF (Commission Implementing Decision of 10 July 2023), the adequacy decision constitutes the transfer mechanism.

(b) Standard Contractual Clauses (SCCs): Where the recipient is not DPF-certified or as a supplementary measure, we rely on the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914, supplemented by a transfer impact assessment.

6.3 You may request a copy of the applicable safeguards by contacting us at the address in Section 1.

7. How Long We Keep Your Data

We retain personal data only as long as necessary for the purposes for which it was collected, or as required by law:

(a) Account and profile data: duration of your membership plus 30 days (to allow for reactivation requests), then deleted or anonymised.

(b) Community content (posts, comments, messages): duration of your membership. The Company’s licence to anonymised derivatives survives termination as described in the Additional Terms of Service.

(d) Live-session recordings and transcripts: duration of the relevant cohort or programme period plus 4 weeks for catch-up review, then deleted or archived without member access.

(e) Billing and tax records (invoices, payment records, VAT data): 7 years from the end of the relevant calendar year, as required by §132 BAO (Bundesabgabenordnung).

(f) Support correspondence: 3 years from resolution of the inquiry.

(g) Certification register (name, cohort identifier, certification date, syllabus year): retained indefinitely for the purpose of external verification of the credential. See Section 7.2 below.

(h) Marketing consent records: retained for the duration of the consent plus 3 years for accountability.

(i) Technical/security logs: 90 days.

(j) Launch waitlist: email address, name, language preference and consent record are kept until the launch notification has been sent and in any event no later than eight weeks after it, then deleted. The consent record itself is retained for 3 years for accountability. You may withdraw at any time by writing to support@aiintelligence.inc, and the entry is deleted.

7.2 The certification register is retained indefinitely because the credential does not expire and third parties (including the credential holder’s clients and employers) may need to verify it. The data retained is limited to the minimum necessary for verification. You may request deletion at any time, but deletion will result in the Company’s inability to verify your credential externally. We will inform you of this consequence before processing any deletion request.

8. Your Rights

8.1 Under the GDPR, you have the following rights in relation to your personal data:

(a) Right of access (Art 15): You may request confirmation of whether we process your data and, if so, a copy of that data together with supplementary information.

(b) Right to rectification (Art 16): You may request correction of inaccurate data or completion of incomplete data.

(c) Right to erasure (Art 17): You may request deletion of your data where it is no longer necessary for the purposes collected, you withdraw consent, or the processing is unlawful. This right is subject to exceptions (e.g., legal retention obligations, defence of legal claims).

(d) Right to restriction (Art 18): You may request that we restrict processing in certain circumstances (e.g., while we verify accuracy following your challenge).

(e) Right to data portability (Art 20): Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.

(f) Right to object (Art 21): You may object to processing based on legitimate interest (Art 6(1)(f)). We will cease processing unless we demonstrate compelling legitimate grounds. You may object to direct marketing at any time, without reason.

(g) Right to withdraw consent (Art 7(3)): Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

8.2 To exercise any right, contact us at: support@aiintelligence.inc. We will respond within one month. If your request is complex or we receive many requests, we may extend this by two further months, but we will inform you within the first month.

8.3 You have the right to lodge a complaint with the Österreichische Datenschutzbehörde (see Section 1.4) or with the supervisory authority of your habitual residence or place of work.

8.4 We will not charge a fee for exercising your rights unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse the request.

9. Automated Decision-Making

9.1 We do not subject you to decisions based solely on automated processing — including profiling — that produce legal effects concerning you or similarly significantly affect you (Article 22(1) GDPR).

9.2 The Matrix and AIVY produce analytical outputs and suggestions. These are informational tools for your professional development. They do not constitute decisions about you, do not affect your access to services, and do not produce legal or similarly significant effects.

9.3 Content moderation decisions (e.g., removal of a post) involve human review and are not solely automated.

10. Children

10.1 The AI-Intelligence platform is a professional service intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18.

10.2 If we become aware that we have collected data from a person under 18, we will delete the relevant account and data without undue delay. If you believe a minor has registered, please contact us immediately.

11. Security

11.1 We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration or destruction. These include encryption in transit (TLS), access controls, and regular security assessments of our platform host.

11.2 No system is completely secure. If we become aware of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with Article 34 GDPR.

12. Changes to This Notice

12.1 We may update this notice from time to time to reflect changes in our processing activities, legal requirements, or platform features. Where changes materially affect your rights, we will notify you by email or through a prominent notice on the platform at least 30 days before the change takes effect.

12.2 The date at the top of this notice indicates when it was last updated. We encourage you to review it periodically.

13. Contact

For any questions about this notice or our data-processing practices:SINGULARITY.INC FlexCoAttn: Dr. Christian ÖhnerSchwemmweg 46, 2100 Leobendorf, AustriaEmail: christian@aiintelligence.incTelephone: +43 664 326 1616