1. Introduction

Refugio AI, Inc. (“Refugio,” “we,” “us,” or “our”) provides software, APIs, and AI-powered tools that enable businesses to operate, automate workflows, and facilitate transactions (the “Services”).

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you:

• Visit our websites

• Use our platform, APIs, or applications

• Interact with businesses that use Refugio AI

2. Roles & Scope (Important)

Depending on how you interact with Refugio AI, we may act as either:

A. Data Controller

We are a data controller when we collect and process personal data for our own purposes, such as:

• Managing accounts

• Providing support

• Improving our Services

B. Data Processor / Service Provider

We act as a data processor (or service provider) when we process data on behalf of our customers (e.g., businesses using Refugio AI to interact with their users or customers).

In those cases:

• We process data according to our customer’s instructions

• Our customers are responsible for how they collect and use personal data

3. Information We Collect

A. Information You Provide Directly

• Name, email address, phone number

• Account credentials

• Company and business information

• Billing and payment details

• Communications with us

B. Information We Collect Automatically

• IP address and approximate location

• Device, browser, and operating system

• Usage data (features used, interactions, logs)

• Cookies and similar technologies

C. Information Processed on Behalf of Customers

When businesses use Refugio AI, we may process data on their behalf, such as:

• Customer or end-user information

• Transactional data

• Communications and workflow data

• AI inputs and outputs

We process this data strictly in accordance with customer instructions.

D. Information from Third Parties

We may receive information from:

• Payment processors

• Identity verification providers

• Analytics and infrastructure partners

4. How We Use Information

We use information we control to:

• Provide, maintain, and improve the Services

• Authenticate users and secure accounts

• Process payments and manage billing

• Provide customer support

• Develop and improve AI models and features

• Detect fraud, abuse, and security incidents

• Comply with legal obligations

When acting as a processor, we use data only as instructed by our customers.

5. How We Share Information

We may share information in the following ways:

A. With Service Providers

We share data with vendors who help operate our Services, such as:

• Cloud hosting providers

• Payment processors

• Analytics tools

• Security and monitoring providers

B. With Customers (Platform Use)

If you interact with a business using Refugio AI, your information may be shared with that business.

C. Legal & Compliance

We may disclose information to:

• Comply with legal obligations

• Respond to lawful requests

• Protect the rights, safety, and security of Refugio AI, our users, or others

D. Business Transfers

If Refugio AI is involved in a merger, acquisition, or sale, your information may be transferred as part of that transaction.

We do not sell personal data.

6. AI & Data Usage

Refugio AI uses artificial intelligence to power features such as:

• Workflow automation

• Data processing and analysis

• Recommendations and outputs

Important:

• AI outputs may not always be accurate or complete

• Users are responsible for reviewing outputs before relying on them

Model Training

We may use data to improve our models and Services unless restricted by contract or applicable law.

Customers may have the ability to opt out of certain data uses.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to:

• Maintain sessions

• Understand usage and performance

• Improve user experience

You can control cookies through your browser settings.

8. Data Retention

We retain personal data only as long as necessary to:

• Provide the Services

• Comply with legal obligations

• Resolve disputes

• Enforce agreements

Retention periods may vary depending on the type of data and context.

9. Data Security

We implement reasonable administrative, technical, and physical safeguards, including:

• Encryption in transit and at rest

• Access controls and authentication

• Monitoring and logging systems

No system is completely secure, and we cannot guarantee absolute security.

10. Your Privacy Rights

Depending on your location, you may have rights to:

• Access your data

• Correct inaccurate data

• Delete your data

• Restrict or object to processing

• Request data portability

California (CCPA/CPRA)

California residents may also have rights to:

• Know what personal data is collected and shared

• Request deletion of personal data

• Opt out of certain data sharing

To exercise rights, contact us below.

11. International Data Transfers

We may process data in the United States and other countries.

Where required, we implement safeguards such as:

• Standard contractual clauses

• Equivalent legal mechanisms

12. Children’s Privacy

Our Services are not intended for individuals under 18. We do not knowingly collect personal data from children.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If changes are material, we will provide notice via email or through the Services.

14. Contact Us

Refugio AI
Email: hola@refugio.ai