Creomind Privacy Policy

1. Introduction

Creomind ("Creomind," "we," "us," or "our") is committed to protecting the privacy and security of every individual who interacts with our services, our website, and the archives and Creomind Cognitive Models we build. This Privacy Policy explains how we collect, use, store, share, and protect personal information, including the deeply sensitive data involved in creating a Cognitive Model.

We treat the data we work with as among the most personal information that has ever existed. This policy reflects that responsibility.

By accessing our website, joining our waitlist, or engaging Creomind for our services, you acknowledge that you have read and understood this Privacy Policy.

2. Scope of This Policy

This Privacy Policy applies to:

• Visitors to our website (creomind.ai and any associated subdomains)
• Individuals who join our waitlist or submit inquiries
• Clients who engage Creomind for our services ("Family Members")
• Individuals whose archives and Cognitive Models are created ("Subjects")
• Any other person whose personal information we collect in connection with our operations

This policy does not apply to third-party websites, services, or applications that may be linked from our platform.

3. Information We Collect

We collect information in the following categories:

3.1 Information You Provide Directly

Waitlist and inquiry information: When you join our waitlist or contact us, we collect your name, email address, the relationship of the proposed Subject, the Subject's living status, your timeline, and any additional information you choose to share.

Account and onboarding information: If you become a client, we collect billing information, identity verification documents, contact details for designated family representatives, and emergency contact information.

Consent documentation: For every Subject, we collect formally documented and recorded consent, including video and written records establishing the Subject's authorization to create an archive and Cognitive Model.

3.2 Subject Source Material

For Subjects whose archives and Cognitive Models we create, we collect, exclusively with documented consent, the following categories of personal data:

• Audio recordings (interviews, voice notes, voicemails, ambient conversations)
• Video recordings (interviews, family footage, behavioral observations)
• Written materials (text messages, emails, journals, letters, social media archives, written reflections)
• Photographs
• Biographical information (life events, relationships, opinions, values, beliefs)
• Behavioral and personality data (decision patterns, idiosyncrasies, communication styles)
• Family-submitted memories and contextual information

This material constitutes some of the most sensitive personal data possible, and we treat it accordingly.

3.3 Information Collected Automatically

When you use our website, we may collect:

• Device information (browser type, operating system, device identifiers)
• Usage data (pages viewed, time spent, navigation paths)
• IP address and approximate geographic location
• Cookies and similar tracking technologies (see Section 11)

3.4 Information from Third Parties

We may receive information from:

• Family members submitting source material on behalf of a Subject
• Service providers and processors who support our operations
• Public sources, only when explicitly relevant to a project and with consent

4. How We Use Information

We use the information we collect for the following purposes:

4.1 Service Delivery

• To build, maintain, and refine each Subject's archive and Creomind Cognitive Model
• To facilitate access for designated Family Members
• To provide updates, continuity services, and ongoing maintenance
• To deliver customer support and respond to inquiries

4.2 Operations

• To process applications and manage the waitlist
• To verify identity and prevent unauthorized access
• To process payments and manage billing
• To comply with legal obligations and respond to lawful requests

4.3 Research and Improvement

We may use aggregated, fully de-identified data to improve our methodologies and publish research findings. Outside of that aggregated, de-identified use, we do not use an individual Subject's data to train external models, third-party AI systems, or any system outside of that Subject's own private Cognitive Model.

4.4 Communications

• To send service updates, onboarding communications, and policy changes
• To respond to your inquiries and provide support
• To send waitlist updates and availability notifications

You may opt out of non-essential communications at any time.

5. Legal Basis for Processing

Where applicable under the EU General Data Protection Regulation (GDPR), the UK GDPR, or similar legislation, we process personal information on the following legal bases:

• Consent: For Subject source material and sensitive personal data, we rely exclusively on explicit, informed, documented consent.
• Contract: To deliver services to clients who have engaged Creomind.
• Legal obligation: Where processing is required to comply with applicable law.
• Legitimate interest: For routine business operations, security, and service improvement, only where such interests are not overridden by your fundamental rights.

6. The Consent Framework

Consent is the foundation of our work. The following principles are non-negotiable:

Subject consent is mandatory. No archive or Cognitive Model is constructed without the formally documented, recorded, and verified consent of a living Subject. We do not build a new archive or Cognitive Model from the material of a deceased person. Posthumous provisions apply only to archives, Cognitive Models, and data that were created during the Subject's life, governing access, continuity, and deletion after death in accordance with the Subject's documented wishes.

Consent is informed. Subjects are provided with full information about what data will be collected, how it will be used, who will have access, how long it will be retained, and what their rights are.

Consent is revocable. Living Subjects may withdraw consent at any time, in which case ongoing data collection will cease and existing data will be handled according to the Subject's documented wishes.

Consent governs continuity. Subjects determine, in advance, what happens to their archive and Cognitive Model after their death, including who may access it, whether it may be updated, and under what circumstances it should be retired.

7. Data Sharing and Disclosure

We do not sell, rent, or trade personal information. We share information only in the following limited circumstances:

7.1 Authorized Family Members

A Subject's archive and Cognitive Model are accessible only to family members or representatives explicitly designated and authorized by the Subject (or, where applicable, by the Subject's estate).

7.2 Service Providers

We engage carefully selected service providers to support our operations, including cloud infrastructure, encryption services, payment processors, and email services. These providers are contractually bound to protect your information and use it solely to deliver services to Creomind.

7.3 Legal Requirements

We may disclose information when required to do so by law, court order, or valid legal process. Where legally permitted, we will notify affected individuals before disclosure.

7.4 Safety and Security

We may disclose information when we reasonably believe disclosure is necessary to protect the safety of any person, prevent fraud, or address security threats.

7.5 Business Transfers

In the event of a merger, acquisition, restructuring, or transfer of assets, personal information may be transferred to the successor entity, subject to the same protections set out in this policy. We will notify affected individuals of any such transfer in advance.

We do not sell personal data, including Subject source material, to any third party.

8. International Data Transfers

Creomind's infrastructure is hosted on Microsoft Azure, and personal information may be processed in more than one country. Where personal information is transferred outside the country in which it was collected, we rely on the data protection terms offered by our infrastructure and service providers, together with technical measures such as encrypted connections and encryption at rest provided by the underlying services.

We are reviewing our data flows and provider agreements to confirm the specific transfer mechanism that applies to each flow. Until that review is complete, we do not state that every transfer relies on a particular legal mechanism. You may request current information about the safeguards applicable to your data by contacting us at the address listed in Section 16.

9. Data Security

Current practice. Creomind's infrastructure is hosted on Microsoft Azure. We use safeguards appropriate to the sensitivity of the information we process. Data transmitted between users and Creomind is protected using encrypted connections such as HTTPS/TLS. Applicable data stored within Creomind's Azure infrastructure is protected using encryption at rest provided by the underlying Azure services. Multi-factor authentication is used to protect administrative access to Creomind's Azure environment and relevant administrative accounts. Our security architecture and operational controls will continue to evolve as the service develops.

Design principle. Creomind is being designed around data minimisation, restricted access, separation of private archive data from development and research environments, and lifecycle controls appropriate to the sensitivity of the information. As the service develops, we intend to formalise access restrictions and logging, isolation between engagements, and documented operational security procedures.

Creomind does not operate its own physical data-center infrastructure. Physical infrastructure is operated by Microsoft Azure, and we do not present Microsoft's controls or certifications as controls operated by or certifications held by Creomind.

No system is completely secure. If we become aware of a security incident affecting personal data, we will take appropriate steps to contain and address it and provide notifications where required by applicable law.

10. Data Retention

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

Subject source material, archives, and Cognitive Models: Retained for the duration specified by the Subject's documented consent and continuity instructions. By default, archives and Cognitive Models are designed to be maintained for the lifetime of the engaging family, and beyond, where authorized.

Waitlist and inquiry data: Retained while your inquiry remains active and for a limited period afterwards, unless you request earlier deletion.

Account and billing data: Retained for the duration of your engagement with Creomind and for the period required by applicable tax, accounting, and regulatory obligations.

Website usage data: Retained in identifiable form only for as long as needed for the purpose it was collected for.

We are documenting a formal retention schedule with defined periods for each category, and we will publish those periods here once confirmed.

You may request deletion of your information at any time, subject to limitations described in Section 12. When deletion is requested, Creomind deletes or schedules deletion of applicable personal data from active systems in accordance with its technical and legal retention requirements. Residual copies may persist temporarily in backups where technically necessary and are removed according to the applicable backup lifecycle. We do not claim that deletion is immediate or irreversible across every backup copy.

11. Cookies and Tracking Technologies

Our website uses a minimal set of cookies and similar technologies to operate the site, analyze usage, and improve performance. We do not use advertising or behavioral tracking cookies.

The categories we use:

• Essential cookies: Required for the website to function (e.g., session management).
• Analytics cookies: Help us understand how visitors use our site, in aggregated and de-identified form.
• Preference cookies: Remember your settings and preferences.

You may control cookie preferences through your browser settings or our cookie consent banner. Disabling certain cookies may limit functionality.

12. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right of access: To request a copy of the personal information we hold about you.
• Right of rectification: To correct inaccurate or incomplete information.
• Right to erasure: To request deletion of your information, subject to legal and contractual constraints.
• Right to restrict processing: To request that we limit how we use your information.
• Right to data portability: To receive your information in a structured, machine-readable format.
• Right to object: To object to certain types of processing, including for direct marketing.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
• Right to lodge a complaint: With the relevant data protection authority.

To exercise any of these rights, please contact us using the information in Section 16. We will respond within the timeframe required by applicable law (typically 30 days).

Special note on Subject data: For archives and Cognitive Models built on behalf of a Subject, the rights above are exercised by the Subject (during life) or by the Subject's authorized representatives (after death), in accordance with the Subject's documented consent and continuity instructions.

13. Children's Privacy

Creomind's services are available only to adults aged 18 or over. We do not create archives or Cognitive Models for minors and do not knowingly collect personal information from individuals under 18. If we become aware that we have collected information from a minor, we will promptly delete it.

14. Sensitive Personal Information

We recognize that the data we process, including biometric data (voice prints), behavioral data, and detailed personal histories, constitutes "sensitive personal information" under most data protection regimes (including GDPR Article 9, the California Privacy Rights Act, and similar laws).

We process this data exclusively under the explicit consent of the Subject or their authorized representatives, with elevated security controls, and not for any purpose outside the Subject's archive and Cognitive Model, except as described in Section 4.3.

15. Posthumous Data

Posthumous provisions apply only to data, archives, and Cognitive Models created during a Subject's life. We do not create a new archive or Cognitive Model from the material of a deceased person. For archives and Cognitive Models that already exist at the time of the Subject's death, we treat their continued processing with the same care we apply to living Subjects, and in many cases with heightened care:

• The Subject's documented continuity instructions govern all posthumous use of the existing archive and Cognitive Model
• Designated family representatives are bound by the Subject's stated wishes
• Material submitted by family after a Subject's death is added to the archive and does not modify the Subject's Cognitive Model, unless the Subject explicitly authorized that possibility in their documented instructions
• Families may not modify, share, or repurpose a Subject's archive or Cognitive Model in violation of the Subject's documented intent

16. How to Contact Us

For any questions, concerns, or requests related to this Privacy Policy or your personal information:

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or the evolution of our services. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify affected individuals by email or through prominent notice on our website
• Where required by law, obtain renewed consent for changes that materially affect how we process personal data

We encourage you to review this Privacy Policy periodically.

18. Jurisdiction-Specific Disclosures

18.1 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act and the California Privacy Rights Act, including the right to know what personal information we collect, the right to delete personal information, the right to correct inaccurate information, the right to opt out of the sale or sharing of personal information (we do not sell or share personal information for cross-context behavioral advertising), and the right to limit use of sensitive personal information.

To exercise these rights, contact info@creomind.ai.

18.2 European Economic Area, United Kingdom, and Switzerland

Individuals in the EEA, UK, and Switzerland have rights under the GDPR, UK GDPR, and Swiss Federal Act on Data Protection respectively. The legal basis for our processing is described in Section 5. You have the right to lodge a complaint with your local supervisory authority.

18.3 Other Jurisdictions

We comply with data protection laws applicable in the jurisdictions where we operate. Where local law provides additional rights, those rights are respected.

19. Closing Statement

The work we do at Creomind is unprecedented. We are building archives and Cognitive Models drawn from the most intimate dimensions of a person: their voice, their thinking, their memory, their perspective. We understand that the trust required to do this work is profound, and we have designed every aspect of our operations to be worthy of it.

If at any point you feel we have fallen short of the standards described in this policy, we want to hear from you. Our work depends on it.

Creomind