Privacy Policy

1. Version and Effective Date

Version: 2.0

Effective date: May 29, 2026

This version supersedes all previous versions of the Privacy Policy for the SmartSplitAI public website.

2. Introduction

SmartSplitAI LLC respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit the public website smartsplitai.net (the "Website").

This Policy is provided for transparency and describes our personal data practices for the public website.

3. Scope of This Policy

This Policy applies only to the SmartSplitAI public website at smartsplitai.net. Separate SmartSplitAI products, application environments, or customer workspaces may be governed by separate privacy notices, terms, or agreements.

4. Applicable Privacy Laws

Depending on your location and applicable circumstances, the processing of your personal data may be governed by one or more of the following frameworks:

• U.S. federal and state privacy laws, where applicable;
• the EU General Data Protection Regulation (GDPR) and the UK GDPR, where applicable;
• Brazil's General Data Protection Law (LGPD) and other LATAM privacy laws, where applicable;
• Russian Federal Law No. 152-FZ "On Personal Data" and related regulations, where applicable.

References in this Policy to rights or obligations are made on the basis that the relevant law applies to you. We do not claim that the Website is fully compliant with every privacy regime in every jurisdiction.

5. Who Is the Data Controller / Operator

For purposes of applicable privacy and data protection laws, the controller/operator for the public website may include SmartSplitAI LLC and/or Individual Entrepreneur Sergey V. Stepanov, depending on the user's location, the communication channel used, and the entity responsible for handling the relevant request.

Contact for all data protection inquiries: info@smartsplitai.net

6. What Personal Data We May Collect

We may collect the following categories of personal data when you interact with the Website:

• Contact information — such as your name, email address, and any other contact details you voluntarily provide when you reach out to us via email at info@smartsplitai.net.
• Messaging and social platform data — if you contact us through third-party communication channels:
  • Telegram: your Telegram username, public profile information, and message content;
  • WhatsApp: your phone number, profile name, and message content;
  • LinkedIn: your LinkedIn profile information and message content.
• Message content — the content of any inquiry, request, or communication you send to us through any channel.
• Technical logs — standard server logs that may include IP address, browser type and version, device type, operating system, referring/exit pages, date and time stamps, and pages visited. These are collected automatically by the web server and are typical for any website.
• Language preference — retained technically (e.g., URL path) to serve the correct language version of the Website.
• Information submitted through future contact forms — if contact or demo-request forms are added to the Website in the future.

7. What We Do Not Collect on the Public Website

The public website does not currently provide or process:

• user accounts or registration;
• paid subscriptions or payment information;
• document uploads or file storage;
• contract analysis or AI processing of user-submitted legal documents;
• real-time backend chat or AI-generated responses to user queries;
• marketing cookies, analytics cookies, advertising pixels, or tracking scripts.

If any of these features are added to the public website in the future, this Privacy Policy will be updated accordingly before or at the time of their introduction.

8. How We Use Personal Data

We use the personal data we collect for the following purposes:

• To respond to your inquiries, questions, and requests submitted via email, Telegram, WhatsApp, LinkedIn, or any other contact channel.
• To provide information about our company, products, and services that you have requested.
• To operate, maintain, and improve the Website, including through analysis of aggregated technical log data.
• To ensure the security and integrity of the Website.
• To comply with legal obligations and respond to lawful requests from public authorities.

9. Legal Bases for Processing

Where applicable data protection laws require a legal basis, we process personal data on the following grounds:

• Consent — where you have given clear consent for us to process your personal data for a specific purpose (e.g., when you voluntarily contact us).
• Legitimate interests — where processing is necessary for our legitimate interests, such as responding to inquiries, maintaining Website security, and improving our services, and those interests are not overridden by your rights and interests.
• Legal obligation — where we need to comply with a legal or regulatory obligation.

10. Contact Channels: Email, Telegram, WhatsApp, LinkedIn

When you contact us through third-party messaging or social platforms, you are also subject to the privacy policies of those platforms. We recommend that you review them:

• Telegram: telegram.org/privacy
• WhatsApp: whatsapp.com/legal/privacy-policy
• LinkedIn: linkedin.com/legal/privacy-policy

We process messages received through these channels solely to respond to your inquiry. We do not sell, share, or use your messaging data for marketing, profiling, or automated decision-making.

11. AI Assistant / Chatbot Notice

The public website may include a static AI-assistant-style interface for navigation and informational purposes. At the current stage:

• the website assistant does not send user messages to an external AI API or backend service;
• the website assistant does not provide legal, tax, accounting, or financial advice;
• the website assistant does not store, log, or process user messages on a server.

If the assistant is upgraded to a functional AI chatbot in the future, this Policy will be updated, and users will be informed through an appropriate notice.

12. Cookies and Similar Technologies

At the current stage, the public website does not use:

• analytics cookies (e.g., Google Analytics);
• advertising cookies or remarketing pixels;
• marketing automation cookies;
• social media tracking pixels.

The Website may use strictly necessary technical mechanisms (such as server session logs) that are essential for the operation and security of the Website and do not require consent under most privacy frameworks.

If analytics or advertising tools are added later, this Policy will be updated and, where required by applicable law, a cookie consent mechanism will be provided.

13. Data Sharing and Service Providers

We do not sell, rent, or trade your personal data to third parties.

Where we directly engage hosting, infrastructure, or email providers, they may process data to help us operate the Website. Such providers are contractually bound to process personal data only on our instructions and in compliance with applicable data protection laws.

Third-party communication platforms such as Telegram, WhatsApp, and LinkedIn process data under their own privacy policies. We do not control their independent data processing practices.

We may also disclose personal data if required by law, court order, or governmental regulation, or to protect the rights, property, or safety of SmartSplitAI LLC, our users, or others.

14. International Data Transfers

Because the Website, hosting providers, communication tools, and service providers may operate in different countries, your personal data may be transferred to and processed in countries outside your country of residence, including the United States.

Where required by applicable law, we will seek to use reasonable and applicable safeguards for international data transfers.

15. Data Retention

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

• Inquiry messages — for the duration of the communication and a reasonable period thereafter to maintain a record of correspondence, not exceeding 2 years unless a longer period is required by law or for legitimate business purposes.
• Technical server logs — retained for a limited period (typically up to 30 days) for security and operational purposes, then deleted or anonymized.

When personal data is no longer needed, we will securely delete or anonymize it.

16. User Rights

Depending on your jurisdiction and applicable law, you may have the following rights regarding your personal data:

• Right of access — the right to request a copy of the personal data we hold about you.
• Right to rectification — the right to request correction of inaccurate or incomplete personal data.
• Right to erasure — the right to request deletion of your personal data, subject to certain exceptions.
• Right to withdraw consent — where processing is based on consent, you may withdraw that consent at any time.
• Right to object — the right to object to processing based on legitimate interests.
• Right to restriction — the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to data portability — where applicable, the right to receive your data in a structured, commonly used format.
• Right to lodge a complaint — the right to file a complaint with a supervisory authority in your country of residence, where applicable.

To exercise any of these rights, please contact us at info@smartsplitai.net. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.

17. Security Measures

We implement reasonable technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures are appropriate to the nature and scope of the data we process on the public website.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

18. Children's Privacy

The Website is not directed to individuals under the age of 16, and we do not knowingly collect personal data from children. If we become aware that a child under 16 has provided us with personal data, we will take steps to delete such information. If you believe a child has provided us with personal data, please contact us at info@smartsplitai.net.

19. Third-Party Links

The Website contains links to third-party websites and services, including Telegram, WhatsApp, LinkedIn, and separate SmartSplitAI product environments. We are not responsible for the privacy practices, content, or security of those third-party sites. We encourage you to review the privacy policies of any third-party services you use.

20. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the features of the Website. When we make changes, we will update the "Effective date" at the top of this Policy.

We encourage you to review this Policy periodically. Material changes will be communicated through a notice on the Website where reasonably practicable.

21. Contact

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

SmartSplitAI LLC
4030 Wake Forest Rd, Suite 349
Raleigh, NC 27609, USA
info@smartsplitai.net