PRIVACY POLICY

Introduction

This Privacy Policy outlines how Zenith Way, s.r.o., Company ID: 56966954 (hereinafter referred to as “controller”, “we”, “our”, or “us”) collects, uses, and shares your personal data when using our AI mentor service AURORA mentor (hereinafter referred to as “AURORA mentor” or “Service”) via the Telegram communication platform.

Personal Data Controller

The controller of your personal data according to Article 4 point 7 of the Regulation of the European Parliament and Council (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as GDPR) is: Zenith Way, s.r.o., Company ID: 56966954, Východná 26, Trenčín 91108, email: info@auroramentor.com

What Information We Collect

1. Information you provide to us:
– Text messages and commands you send to AURORA mentor
– Voice messages you send to AURORA mentor
– Images you send to AURORA mentor

2. Information we collect automatically:
– Usage data (e.g., usage frequency, features used)
– Information from your Telegram profile (e.g., name, language)
– Chat history and all information contained in your messages

How We Use Your Information

We use the collected information to:
– Provide, maintain, and improve the Service
– Process and complete transactions
– Send technical notices and support messages
– Respond to your comments, questions, and requests

Data Storage and Security

– We use AWS DynamoDB to store encrypted user data and chat history.
– We use Pinecone to store encrypted chat history.
– All data is encrypted both in transit and at rest.
– Data provided to AI models is not stored or used for training by model providers.
– We never directly access or read chat history or user information. Data is securely encrypted in our database and decrypted only temporarily for communication with AI models.

Data Retention Period

We retain your data as long as your account is active, or as necessary to provide the Service. We delete your data upon request or upon termination of the Service.

Deleting specific messages from our database is not possible within the Telegram bot, as the Telegram API does not provide an endpoint to notify us that you deleted a message from the conversation.

Third-Party Services

We use the following third-party services:
– OpenAI, Anthropic, and fireworks.ai APIs for generating responses
– Pinecone for retrieving relevant chat history
– Telegram for message delivery
– LemonSqueezy, FAPI.cz, and Stripe for payment processing
– AWS Lambda for data processing and chatbot response generation
– Hume.ai for voice call processing (note: audio is not stored on their servers)

Each of these services has its own privacy policies and practices.

Legal Basis for Processing

We process your personal data based on the following legal grounds:
1. Your consent to the processing of personal data according to Article 6(1)(a) of the GDPR
2. Performance of a contract between you and the controller according to Article 6(1)(b) of the GDPR
3. Processing is necessary for compliance with a legal obligation of the controller according to Article 6(1)(c) of the GDPR

Recipients of Personal Data

A recipient is anyone to whom personal data is provided, regardless of whether they are a third party. A public authority that processes personal data on the basis of a special regulation is not considered a recipient.

– These are persons who participate in the delivery of services and implementation of payments based on the contract
– The controller does not provide, publish, or make personal data accessible to third countries outside the EU and EEA

Conditions for Securing Personal Data

The controller declares that it has adopted appropriate personnel, technical, and organizational measures to ensure the protection of personal data.

The controller has adopted technical measures to secure data repositories and repositories of personal data in electronic and written form.

The controller declares that only persons authorized by it have access to personal data.

Your Rights

Under the conditions set out in the GDPR, you have:
– The right to access your personal data according to Art. 15 GDPR
– The right to rectification of personal data according to Art. 16 GDPR
– The right to restriction of processing
– The right to erasure according to Art. 17 GDPR
– The right to object according to Article 21 GDPR
– The right to data portability according to Article 20 GDPR
– The right to withdraw consent (electronically, or to the correspondence address)
– The right to lodge a complaint with a supervisory authority if you believe that your rights to personal data protection have been violated

How Can You Exercise Your Rights?

Right to Access Data
You have the right to know if we process your personal data. If we do, you can request access to them. Based on your request, we will issue a confirmation with information about the processing of your personal data. You can submit your request electronically to the email address info@auroramentor.com.

Right to Rectification
You have the right to ensure that your personal data that we process is correct, complete, and up-to-date. If your personal data is incorrect or out-of-date, you can request correction or completion electronically to the email address info@auroramentor.com.

Right to Erasure
Under certain circumstances, you have the right to have your personal data deleted. You can request the deletion of your data at any time.

We will delete your personal data if:
– we no longer need your personal data for the purpose for which you provided them to us,
– you withdraw your consent,
– you object to the processing of your personal data,
– we process your personal data unlawfully,
– personal data must be deleted to comply with a legal obligation,
– if you are a child, or a parent of a child who consented to the processing of personal data over the internet.

Right to Restriction of Processing
You can request that we restrict the processing of your personal data. If we comply with your request, we will only store your personal data and will not process them further.

The processing of your data will be restricted if:
– you inform us that your personal data is incorrect, until we verify its accuracy,
– we process your personal data unlawfully, but you do not agree to their deletion and instead request that we restrict the processing of your personal data,
– we no longer need your data, but you need it to establish, exercise, or defend your legal claims,
– you object to the processing of your personal data, until we verify whether our legitimate interests outweigh your reasons.

Right to Data Portability
You have the right to request that we provide you with your personal data in electronic form that allows you to easily transfer the data to another company. You can also request that we transfer your personal data directly to your chosen company. We will comply with your request if you provided us with the personal data directly and gave us consent to process it.

Right to Object
You have the right to object to our processing of your personal data.

If we process your personal data in the following cases:
– based on our legitimate interest,
– creating a customer profile,
you can object to their processing if you have personal reasons for doing so.

How Can You Exercise These Rights?

You can contact us with your request by email at: info@auroramentor.com

If you believe that your rights to the protection of personal data have been violated, you have the right to lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection at the address:

Hraničná 12
820 07 Bratislava 27
Slovak Republic

Identification details:
Company ID: 36064220
Tax ID: 2021685985

Secretariat of the Office:
+421 /2 3231 3214

E-mail: statny.dozor@pdp.gov.sk

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will inform you of any changes by publishing the new Privacy Policy on this page and updating the “Last updated” date.

This Privacy Policy is effective from May 30, 2025.

Contact Us

If you have any questions regarding this Privacy Policy, please contact us at info@auroramentor.com.