Related navigation:

• Prifina Privacy Policy
• Prifina Terms of Use

Prifina Privacy Policy

Last Updated: March 24, 2025   

​At Prifina, we believe that your data belongs to you. We built this platform to empower you with your data. You own your data - it is your modern day luxury. 

Your data should be on your side. Your data should create the most value for you. Therefore, our goal is to build a new data ecosystem where you can unlock new opportunities with your own data. 
​
Your privacy is important to us. This Privacy Policy explains what information Prifina collects, how we use and share it, and your rights concerning that information. This policy is integrated into the Prifina Terms of Use, and by using the Services, you agree to the data practices described here. If you do not agree, please do not use the Services.

We will never sell your data to third parties.
We are committed to handling your personal data in compliance with applicable privacy laws, including the California Consumer Privacy Act (CCPA) and the EU General Data Protection Regulation (GDPR) where applicable.

1 Information We Collect
We may collect different types of information from and about you when you use Prifina:

1.1 Information You Provide Directly:

• Account Information: When you register as a user (whether as an AI Twin Owner, AI Twin User, or Hub Participant), we may collect personal information such as your name, email address, username, password, and any profile details you provide. AI Twin Owners may also need to provide additional info such as organization name, billing address, and payment payout details (e.g., PayPal or bank information) if they will receive payments.
• Content and Communications: We collect any content you submit to the platform. This includes interactions with AI Twins (e.g., the questions you ask and the AI’s responses), posts or listings you create on the Hub marketplace, messages or communications you send to Prifina (like support requests or feedback), and any other information you intentionally share with us.
• Transaction Information: If you make a purchase or financial transaction on the Hub marketplace, our payment processor will collect payment information (such as credit card number, expiration date, security code, and billing address). Prifina itself may receive limited information about the transaction, such as your name, the product purchased, the date/time of the transaction, and the amount. (Note: We do not store your full payment card details; payments are handled by third-party processors compliant with PCI-DSS.)

1.2 Information Collected Automatically:
When you use our Services, Prifina (and our service providers) may automatically collect certain technical and usage data:

• Usage Logs: This includes details of your use of the Services, such as timestamps of logins, the AI Twins you interact with, your actions on the platform (e.g., creating an AI Twin, viewing a marketplace listing), and feature usage statistics. We may log the content of AI interactions for service functionality and improvement (as permitted by law and as described in this policy).
• Device and Network Information: We collect information about the device and internet connection you use to access Prifina. This may include your device type, operating system version, browser type, IP address, unique device identifiers, and network information. We may use IP addresses to infer approximate location (e.g., city, country) which helps with regional settings and compliance (for example, to display GDPR consent forms if you’re in the EU).
• Cookies and Similar Technologies: Prifina uses cookies, web beacons, and local storage to remember your preferences and settings, authenticate users, and measure and analyze usage. For example, we may use cookies to keep you logged in or to track aggregate usage of features. You can control cookies through your browser settings and other tools, but disabling cookies may affect your experience (like requiring you to log in more frequently). Our use of cookies and analytics is further detailed in Section 7.6.

1.3. Information from Third Parties:
We may receive information about you from third-party sources, if applicable:

• If you login via a third-party account (like Google, Apple, or others), we receive basic profile info from them such as your name and email as permitted by that service and authorized by you.
• If you are an AI Twin User, an AI Twin Owner might provide us with data about your interactions (for example, if they maintain logs or analysis outside of Prifina and then import some results to our platform for improvements or dispute resolution).
• If you participate in the Hub marketplace, we may receive fraud detection or verification information about you from payment processors or vetting services (to prevent fraudulent transactions).

We treat information from third parties with the same care as information you provide directly, and as outlined in this Privacy Policy.

2 How We Use Your Information
Prifina uses the collected information for the following purposes:

• To Provide and Maintain the Services: We use personal data to allow you to login and use Prifina, to facilitate interactions with AI Twins, to enable marketplace transactions, and to generally operate the platform. For example, your account info is used to identify you, your AI Twin input is used to generate AI responses, and transaction info is used to process payments.
• To Personalize and Improve the Experience: We may use data to customize content (like recommending relevant AI Twins or marketplace listings), and to improve our AI models and platform. For instance, we might analyze aggregated interaction logs to improve AI response quality or to develop new features. If we use your conversation logs with an AI to improve the AI or our services, we will either remove personally identifiable information or obtain necessary permission as required by law.
• To Communicate with You: We use contact information (email, etc.) to send you service-related communications. This includes confirmations of actions (like account creation, purchases), important system or policy updates, security alerts (like new login to your account), and customer support responses. We may also send newsletters or product announcements, but you will have the ability to opt-out of marketing emails if they are not essential to the service.
• To Ensure Security and Prevent Fraud: Information like device data, IP addresses, and usage patterns help us detect and prevent fraudulent or abusive activity. For example, we might use IP and device fingerprints to detect if someone is creating multiple fake accounts or if an account login seems suspicious.
• To Enforce Our Terms and Policies: We may review and use data (including user reports and AI logs) to investigate potential violations of our Terms of Use (such as misuse of the service, infringement, or harmful behavior) and to enforce our policies. This might involve using automated tools or human review to monitor for prohibited content.
• To Comply with Legal Requirements: We will use and disclose data as necessary to comply with our legal obligations. For example, to respond to lawful requests by public authorities, to meet national security or law enforcement requirements, to respond to subpoenas or court orders, or to defend our legal rights in litigation.
• For Other Purposes With Your Consent: If we want to use your information for a purpose that is materially different from the ones above, we will ask for your consent. For instance, if we ever wanted to publicize a particular user’s success story or share your personal data with a third party for their own marketing, we would only do so if you agreed.

Our use of personal data is conducted on the legal bases permitted by applicable law: with your consent where required, to fulfill our contract with you (Terms of Use), to comply with legal obligations, and for our legitimate interests in operating and improving our Services (balanced against user privacy rights).

3 How We Share Your Information
Prifina respects your privacy and shares personal information only in limited situations:

• With Service Providers: We share information with third-party vendors who perform functions on our behalf to help run our business. This includes cloud hosting providers (for data storage and servers), payment processors (for handling billing transactions and payouts), analytics services (to help us understand usage of our Services), and communication tools (for sending emails or support chats). These providers are contractually bound to process personal data only as needed to provide their services to us and to maintain confidentiality and security of your data.
• With AI Twin Owners (for AI Twin User interactions): If you engage with an AI Twin that is owned by a third-party AI Twin Owner, certain data from those interactions may be shared with that owner. This can include the content of your prompts and the AI’s responses, and possibly your user ID or profile information (e.g., user name) if needed to manage the service. AI Twin Owners are required by our Terms (Section 3.2) to handle any personal data they receive in compliance with privacy laws. For example, an AI Twin Owner might receive conversation logs to improve the AI’s performance or to address user inquiries. We share this data to facilitate the service you requested (interacting with the AI) and the AI Twin owner’s improvement of it. If you have concerns about an AI Twin’s data handling, please contact us or the AI Twin Owner if contact info is provided.
• Business Transfers: If Prifina is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed in the course of that transaction and/or transferred as part of the completed transaction. If such a transfer happens, the successor’s use of your information will still be subject to this Privacy Policy (unless and until changed under Section 7.7 – Changes to this Policy).
• Legal Compliance and Protection: We may disclose your information if required to do so by law or in a good-faith belief that such action is necessary to (i) comply with a legal obligation (like a subpoena or court order), (ii) protect and defend the rights, property, or safety of Prifina, our users, or the public, (iii) investigate and defend against any third-party claims or allegations, or (iv) enforce our Terms of Use or other agreements or policies.
• Aggregated or De-Identified Data: We may share information that has been aggregated or de-identified (cannot reasonably be used to identify you) for any purpose. For example, we might publish trends about AI usage or share statistics with partners or the public (like “X% of users engage with at least 2 AI Twins daily”) as long as these do not contain personal data.

No Selling of Personal Data: Prifina will never sell your personal information to third parties. We also do not “share” personal information for cross-context behavioral advertising as defined under California law. Any sharing we may do is as described above and for business/operational purposes, not for others’ marketing benefit.

4 Data Security
Prifina takes reasonable and appropriate measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. These measures include technical safeguards (such as encryption of data in transit via TLS, encryption of sensitive data at rest, and access controls limiting who can access personal data) and organizational safeguards (such as employee training on data protection, and policies governing how we handle data).

However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security. You should also play a role in keeping your data secure by maintaining a strong password for your account and logging out of shared devices. If you suspect any unauthorized access to your account or data, please contact us immediately.

In the event of a data breach that affects your personal data, we will notify you and the appropriate authorities as required by law.

5 Data Retention
We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. For example:

• Account information is kept for as long as your account is active. If you delete your account, we will delete or anonymize your personal data within a reasonable period, except to the extent we need to retain it for legal obligations or to resolve disputes.
• AI interaction logs may be stored to improve services and for audit purposes. If these logs contain personal data, and we no longer need them for service improvement, we will either delete the personal components or fully anonymize the logs after a certain period.
• Transaction records are retained to comply with financial and audit requirements.
• Even if you delete content or your account, copies may remain in backup storage for a brief time and logs of past actions (like an audit trail) may be retained for a longer period as needed for legitimate business purposes.

When we have no ongoing legitimate need to use your personal information, we will securely delete it or anonymize it. If deletion is not immediately possible (for example, the data is stored in archived backups), we will securely store it and isolate it from further use until deletion is feasible.

6 Cookies and Tracking Technologies
Prifina uses cookies and similar tracking technologies on our website and platform to enhance user experience and analyze usage. This section explains our use of these technologies:

• What Are Cookies: Cookies are small text files placed on your device that allow us to remember your preferences or actions over time. Some cookies are session cookies (which expire when you close your browser), and others are persistent cookies (which stay on your device for a set period or until deleted).
  
  
• How We Use Cookies: We use cookies for several reasons:
  • Authentication: To keep you logged in as you navigate the platform.
  • Preferences: To remember your settings and preferences (like language, or UI customization).
  • Analytics: To understand how users arrive at and use our platform. We may use third-party analytics tools (like Google Analytics or similar) that set their own cookies to collect information about user interactions in aggregate, helping us improve the site.
  • Functionality: To enable certain features, such as remembering if you’ve seen or dismissed a notification.
• Your Choices: When you first visit, if you’re in certain jurisdictions (like the EU), you may see a cookie consent banner. You can choose which non-essential cookies to accept. Regardless of banner, you can also control cookies through your browser settings. Note that disabling certain cookies can affect the functionality of the Services (for example, if you block authentication cookies, you may not be able to log in).
  
  
• Do Not Track: Some browsers offer a “Do Not Track” (DNT) feature that signals to websites you do not want to be tracked. Currently, there is no universal standard for honoring DNT, and our site does not respond to DNT headers. We instead provide the privacy options described in this policy.
  
  
  

7 Your Rights and Choices
Depending on your jurisdiction, you have certain rights and choices regarding your personal data. Prifina is committed to honoring those rights. This section outlines general rights (like those under GDPR for EU users and CCPA for California users):

Your Data Protection Rights: You have the following rights regarding your personal data:

• Right to Access: You can request confirmation of whether we are processing your personal data, and if so, request a copy of the data.
• Right to Rectification: You can request that we correct or update any inaccurate or incomplete personal data we hold about you. Much of this can be done through your account settings (e.g., updating your profile info).
• Right to Deletion: You can request that we delete your personal data. We will do so unless we need to retain it for legitimate business or legal reasons (as described in Data Retention, Section 7.5). If you delete your account, this typically covers most of this right.
• Right to Restrict Processing: You can ask us to suspend the processing of certain personal data about you, for example if you contest its accuracy or object to our processing.
• Right to Data Portability: You can request a copy of your data in a structured, commonly used, machine-readable format (and ask that we transfer it to another controller where technically feasible). For example, you might request your interaction logs to port to another service.
• Right to Object: You can object to our processing of your personal data when we base it on legitimate interests, including any profiling. If you object, we will consider whether we have compelling legitimate grounds to continue processing (for example, security logs might be needed) or if we must stop. You can always object to use of your data for direct marketing or promotional emails – if you opt-out or unsubscribe, we will honor that without question.
• Right not to be subject to Automated Decisions: Prifina does not make any legal or similarly significant decisions about users solely by automated means. AI Twins may provide automated outputs, but these are controlled by you or other users, not by us making decisions about your rights.

To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before fulfilling certain requests (for example, by confirming you control the email associated with your account). We will respond to requests within the timeframe required by law (GDPR requires 1 month, for instance, which can be extended in certain cases).

Opt-Out of Marketing Communications: If you have subscribed to any optional newsletters or marketing updates, you can opt-out at any time by clicking the unsubscribe link in the email or by adjusting your account notification settings. Note that you will still receive transactional or service messages (like account alerts or policy updates) as these are not marketing.

8 Cross-Border Data TransfersPrifina is headquartered in the United States, and our Services are primarily provided from the U.S. If you are located outside the U.S., your personal data will likely be transferred to and processed in the United States or other countries where we or our service providers operate. These countries may have data protection laws that are different from those of your country of residence and may not be deemed “adequate” by EU authorities.

However, we will take steps to ensure that appropriate safeguards are in place to protect your personal data in accordance with this Privacy Policy. For transfers from the EEA or UK to the U.S. (or other non-EEA jurisdictions), we rely on user’s explicit consent, approved transfer mechanisms such as the European Commission’s Standard Contractual Clauses (SCCs), or we rely on the fact that the transfer is necessary for the performance of a contract (the Terms of Use) between you and us.

By using the Services, you understand that your information will be transferred to the U.S. and other jurisdictions as necessary for the purposes described in this policy.

9 Third-Party Websites and Services
The Services may contain links to third-party websites or integrate with third-party services (for example, an AI Twin might provide a link to a reference article, or the platform may enable login via a third-party account). This Privacy Policy does not apply to information collected on any third-party site or service that is not under Prifina’s control. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party websites or services you visit or use.

10 Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. If we make material changes, we will notify you by posting the updated policy on our site and/or through other communication channels (such as email notification or an in-app alert). The “Last Updated” date at the top will indicate when the latest changes were made.

Your continued use of the Services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. If you do not agree to any updated policy, you should stop using the Services and may request we delete your data as per Section 7.7.

11 Contact Us
If you have questions or concerns about this Privacy Policy, or if you would like to exercise any of your privacy rights, please contact us at:
Email: [email protected]​
Mail: Paul Jurcys, Chief Privacy Officer, Prifina, Inc.,16193 Lewes, Delaware 19958 USA 

We will address your inquiry and, if applicable, work with you to resolve any concern. If you are an EU/EEA resident and you believe we have not adequately resolved an issue, you have the right to lodge a complaint with your local data protection supervisory authority.

By using Prifina’s Services, you acknowledge that you have read and understood these Terms of Use and Privacy Policy, and agree to be bound by them. Thank you for using Prifina! We value your trust and are committed to providing a secure and transparent experience.