Privacy Policy
Effective date: May 20, 2026
We take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of Borko LLC’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to material changes by placing a notice on the Borko LLC website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
Privacy Policy Table of Contents
- Service Availability and Region
- Our Representative in the EU, UK, and Switzerland
- EU-U.S. Data Privacy Framework
- What this Privacy Policy Covers
- Personal Data
- Categories of Personal Data We Collect
- Our Commercial or Business Purposes for Collecting Personal Data
- Other Permitted Purposes for Processing Personal Data
- Categories of Sources of Personal Data
- How We Disclose Your Personal Data
- Sub-processors
- Tracking Tools, Advertising and Opt-Out
- Data Security
- Data Retention
- Personal Data of Minors
- U.S. State Privacy Rights
- Exercising Your Rights under U.S. State Privacy Laws
- EU, UK, and Swiss User Rights
- Hosting and Data Location
- Contact Information
Service Availability and Region
The Services are offered to users in the United States and the European Union, the United Kingdom, Switzerland, Norway, Iceland, and Liechtenstein (together, “EU/EEA”). EU/EEA users are served from Borko LLC’s EU-region infrastructure (Convex eu-west-1) and US users from US-region infrastructure; routing is based on your billing-address country at subscription time and the geographic origin of your incoming messages. Personal Data is processed under GDPR (EU/EEA users) or applicable US state privacy laws (US users).
Our Representative in the EU, UK, and Switzerland
We value your privacy and your rights as a data subject. In accordance with Article 27 of the EU General Data Protection Regulation, Article 27 of the UK GDPR, and the requirements of the Swiss Federal Act on Data Protection, we have appointed Prighter Group, together with its local partners, as our privacy representative and your point of contact for the following regions:
- European Union (EU/EEA)
- United Kingdom (UK)
- Switzerland
Prighter provides an easy way for you to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you wish to contact us through our representative or make use of your data subject rights, please visit: https://app.prighter.com/portal/18075508469.
You may also contact us directly at oriontaraban.ai@protonmail.com. Contacting Prighter does not replace your right to contact us directly or to lodge a complaint with your supervisory authority.
EU-U.S. Data Privacy Framework
Borko LLC has submitted a self-certification application to the U.S. Department of Commerce under the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). Until that self-certification is finalized and Borko LLC appears on the active participant list maintained at https://www.dataprivacyframework.gov/, transfers of personal data from the EU/EEA, the United Kingdom, and Switzerland to the United States in connection with the Services are made in reliance on the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable) or other lawful transfer mechanisms.
Once Borko LLC’s self-certification is finalized and active, Borko LLC will commit to adhere to the EU-U.S. DPF Principles, the UK Extension Principles, and the Swiss-U.S. DPF Principles with respect to personal data received from the EU, the UK (and Gibraltar), and Switzerland in reliance on those frameworks, and the following commitments and mechanisms will apply.
Scope
Once active, Borko LLC’s commitments under the DPF will cover all personal data received from the European Union, the United Kingdom, and Switzerland in reliance on the DPF, other than human resources data.
The DPF Principles
In compliance with the DPF Principles, Borko LLC commits to: (1) Notice — providing notice about the personal data we collect and how we use it; (2) Choice — offering you choices about whether your personal data is disclosed to third parties or used for materially different purposes; (3) Accountability for Onward Transfer — protecting personal data transferred to third parties; (4) Security — taking reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access; (5) Data Integrity and Purpose Limitation — limiting personal data to the information relevant for the purposes of processing; (6) Access — providing you with access to your personal data; and (7) Recourse, Enforcement, and Liability — providing mechanisms to ensure compliance.
Recourse
Once active under the DPF, Borko LLC commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the DPF should first contact Borko LLC at oriontaraban.ai@protonmail.com, or through our Representative as described in the “Our Representative in the EU, UK, and Switzerland” section above.
Borko LLC further commits to cooperate with the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved DPF complaints concerning personal data transferred from the EU, UK, and Switzerland. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.edpb.europa.eu/about-edpb/contact/members_en for more information or to file a complaint. The services of the EU DPAs, UK ICO, and Swiss FDPIC are provided at no cost to you.
Binding Arbitration
Under certain conditions, more fully described on the DPF website at https://www.dataprivacyframework.gov/, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
FTC Enforcement
Once Borko LLC’s certification is active, the Federal Trade Commission will have jurisdiction over Borko LLC’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
Liability for Onward Transfers
In the context of an onward transfer, Borko LLC has responsibility for the processing of personal data it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. Borko LLC remains liable under the DPF Principles if its agent processes such personal data in a manner inconsistent with the DPF Principles, unless Borko LLC proves that it is not responsible for the event giving rise to the damage.
Disclosure Required by Law
Borko LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
| Category | Business or Commercial Purpose(s) | Disclosed To |
|---|---|---|
| Profile or Contact Data (name, email, phone, username, unique identifiers) | Providing, customizing and improving the Services; corresponding with you | Service Providers |
| Payment Data (card type, last 4 digits, billing address) | Providing, customizing and improving the Services; corresponding with you | Service Providers (specifically Stripe, Inc.) |
| Device/IP Data (IP address, device ID, OS, third-party application used) | Providing, customizing and improving the Services; corresponding with you | Service Providers |
| Social Network Data (email, phone, username, IP address) | Providing, customizing and improving the Services; corresponding with you | Service Providers |
| Sensitive Personal Data (mental health information and other sensitive content you voluntarily share in conversations) | Providing, customizing and improving the Services; corresponding with you | Service Providers |
| Inferences Drawn from Other Personal Data Collected (attributes, behavior, predispositions) | Providing, customizing and improving the Services | Service Providers |
| Other Identifying Information You Voluntarily Choose to Provide (emails, letters, texts, communications) | Providing, customizing and improving the Services; corresponding with you | Service Providers |
Our Commercial or Business Purposes for Collecting Personal Data
Providing, customizing and improving the Services:
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
Corresponding with you:
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Borko LLC or the Services.
Other Permitted Purposes for Processing Personal Data
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Borko LLC or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
- When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
- When you use the Services and such information is collected automatically (through Cookies).
- If you use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Third Parties
- Vendors. We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers
These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Analytics providers for web traffic or usage of our Services.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
- Payment processors. Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment. Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.
Sub-processors
We engage the following sub-processors to provide the Services. Each is bound by a written data processing agreement and, where the sub-processor is located outside the EEA/UK/Switzerland, by Standard Contractual Clauses or another lawful transfer mechanism.
- Convex — application hosting and database (EU users hosted in eu-west-1, Ireland; US users hosted in a US region).
- Stripe, Inc. — subscription billing, payment processing, and tax calculation (Stripe Tax / VAT).
- Anthropic — large language model inference for AI conversations. Contractually prohibited from using user inputs or outputs to train its models.
- OpenRouter — large language model routing and inference. Contractually prohibited from using user inputs or outputs to train models.
- ElevenLabs — voice synthesis (text-to-speech). Contractually prohibited from using user inputs or outputs to train its models.
- Sentry — application error monitoring. Conversation content is scrubbed before transmission.
- Vercel Analytics — privacy-focused, cookieless web analytics. Analytics events exclude conversation content.
- Cloudflare — content delivery network, web application firewall, and DDoS protection.
- Proton Mail — hosted email for customer support correspondence (Switzerland).
- Prighter — EU/UK/Swiss Representative under Article 27 GDPR / UK GDPR.
An updated list of sub-processors is available on request. We will provide notice of material changes to this list before they take effect.
Business Partners
These parties partner with us in offering various services. They include businesses that you have a relationship with.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not attempt to reidentify the data and/or disclose such data in a manner that could identify you.
Tracking Tools, Advertising, and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
- Essential Cookies. Required for providing you with features or services that you have requested. Disabling these may make certain features unavailable. These do not require your consent.
We currently use Vercel Analytics for aggregate, cookieless web analytics. We do not currently run advertising cookies, tracking cookies, or non-essential analytics cookies. If we add non-essential Cookies in the future, then for users in the EU, EEA, UK, and Switzerland, where required under the ePrivacy Directive (and equivalent national implementations) and the UK Privacy and Electronic Communications Regulations, we will obtain your prior consent before setting those Cookies.
You can also manage Cookie preferences through your browser settings. To find out more about Cookies generally, including how to manage and delete them, please visit allaboutcookies.org.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. These measures include encryption in transit (TLS 1.2 or higher) and at rest (AES-256), enforced two-factor authentication on production and administrative systems, regional data isolation for EU/UK/Swiss users, and signed data processing agreements with each of our sub-processors. A more detailed description is available in our Technical and Organizational Measures (TOM) document on request.
You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Specifically:
- Account profile and credentials: retained for as long as your account is active. Upon account deletion (whether initiated by you or following extended inactivity), we soft-delete your profile within 7 days and permanently delete it within 30 days, subject to the exceptions below.
- Conversation transcripts, AI-generated coaching profiles, goals, and pipeline traces: retained for as long as you have an active subscription. Upon account deletion, these are soft-deleted within 7 days and permanently deleted within 30 days.
- Payment and tax records: retained for up to 7 years following the transaction, as required by applicable tax and accounting law (in addition to retention by Stripe under its own policies).
- Device / IP and security logs: retained for 30 to 90 days for operational security and debugging purposes.
- Support correspondence: retained for up to 3 years to address recurring issues and to meet consumer-protection record-keeping requirements.
- Records of consent and data-subject requests: retained for up to 3 years to demonstrate compliance with applicable data protection law.
- Sub-processors (e.g., Anthropic, OpenRouter, Stripe, Sentry, Vercel Analytics) retain data per their own retention policies, typically 30–90 days for operational logs. After we delete your data from our systems, residual copies in third-party systems rotate out according to those schedules.
Personal Data of Minors
As noted in the Terms of Use, the Services are intended only for individuals aged 18 or older. We do not target the Services to anyone under 18, and we do not knowingly collect, solicit, or process Personal Data from any individual under 18 years of age, anywhere in the world. If you are under 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn that we have collected Personal Data from a person under 18 years of age, we will delete that information as quickly as possible. If you believe that a person under 18 may have provided Personal Data to us, please contact us at oriontaraban.ai@protonmail.com.
U.S. State Privacy Rights
If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the “Exercising Your Rights under U.S. State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services for our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Please note that your rights may be subject to certain conditions or exceptions in accordance with applicable U.S. State Privacy Laws.
If you have any questions about this section or whether any of the following rights apply to you, please contact us at oriontaraban.ai@protonmail.com.
- Access. You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data. If you are a Minnesota or Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to whom we have disclosed your Personal Data (subject to exceptions in accordance with applicable law).
- Deletion. You may have the right to request that we delete the Personal Data that we have collected about you.
- Correction. You may have the right to request that we correct any inaccurate Personal Data we have collected about you.
- Portability. You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
“Selling,” “Sharing,” or “Targeted Advertising”
Depending on your state of residence, you may have the right to opt out from the “sale,” “share,” or disclosure of your Personal Data for the purposes of targeted advertising. These or similar terms may be defined differently depending on the applicable U.S. State Privacy Law.
You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
We do not sell, share, or process your Personal Data for the purposes of targeted advertising, and have not done so over the last 12 months.
Processing of Sensitive Personal Data
Through the course of using our Services, you may voluntarily share information that constitutes Sensitive Personal Data under applicable privacy laws, including information concerning your mental or emotional health and wellbeing. We collect such information only when you choose to share it with us during conversations with the AI. By using the Services and choosing to share this information, you provide your explicit affirmative consent to our processing of such Sensitive Personal Data for the purpose of providing the coaching Services described in the Terms of Use. We do not use Sensitive Personal Data for any purpose incompatible with these stated purposes, and we do not sell, share, or process Sensitive Personal Data for targeted advertising. You may withdraw your consent at any time by deleting your account, which will discontinue further processing of your Sensitive Personal Data (subject to the Data Retention section above).
We do not knowingly collect Sensitive Personal Data from minors under 18 years of age.
Automated Decision Making and Profiling
To our knowledge, we do not use automated decision making technology or process the Personal Data for the purpose of profiling consumers under 18 years of age.
Anti-Discrimination
We will not discriminate against you for exercising your rights under applicable privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State-Specific Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at oriontaraban.ai@protonmail.com.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit allaboutdnt.com.
Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
Exercising Your Rights under U.S. State Privacy Laws
To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below), must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable privacy laws. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
EU, UK, and Swiss User Rights
If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have certain rights with respect to your Personal Data under the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection (FADP), in addition to the rights described in the EU-U.S. Data Privacy Framework section above. These rights include:
- Right of access — the right to obtain confirmation as to whether we process Personal Data concerning you and, if so, to access that data.
- Right to rectification — the right to have inaccurate Personal Data corrected and incomplete data completed.
- Right to erasure (“right to be forgotten”) — the right to have your Personal Data deleted in the circumstances set out in applicable law.
- Right to restrict processing — the right to limit how we use your Personal Data in certain circumstances.
- Right to data portability — the right to receive your Personal Data in a structured, commonly used, machine-readable format, and to transmit it to another controller.
- Right to object — the right to object to our processing of your Personal Data, including for direct marketing purposes and for processing based on legitimate interests.
- Right to withdraw consent — where we process your Personal Data based on your consent (including for Sensitive Personal Data shared during use of the Services), the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
- Rights related to automated decision-making — the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, except as permitted by applicable law.
- Right to lodge a complaint — the right to lodge a complaint with a supervisory authority. For users in the EU/EEA, this is the data protection authority in your country of residence (see https://www.edpb.europa.eu/about-edpb/contact/members_en). For users in the United Kingdom, this is the UK Information Commissioner’s Office (https://ico.org.uk/). For users in Switzerland, this is the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/).
To exercise any of these rights, please contact us at oriontaraban.ai@protonmail.com. We will respond to your request within the timeframes required by applicable law (generally one month under GDPR/UK GDPR, extendable by two further months where necessary). We may need to verify your identity before responding to your request. You may also exercise your rights through an authorized representative where permitted by applicable law.
Legal bases for processing. Where GDPR or UK GDPR applies, we process Personal Data on the following legal bases: (i) performance of a contract with you (e.g., delivering the Services you have subscribed to); (ii) compliance with our legal obligations; (iii) our legitimate interests in operating, securing, and improving the Services, where these are not overridden by your rights; and (iv) your consent, which is the basis on which we process Sensitive Personal Data you voluntarily share during conversations and for any optional marketing communications. You may withdraw consent at any time as described above.
Hosting and Data Location
The Services run on two regional backends operated by Borko LLC: a US-region backend (United States) for US users, and an EU-region backend (Ireland, eu-west-1) for users in the EU, UK, Switzerland, Norway, Iceland, and Liechtenstein. Your Personal Data is stored on the backend matching the region we assign to you (based on billing-address country at subscription, or phone country prefix for messaging-only trial users); it is not duplicated across regions. Stripe (payment processor), OpenRouter / Anthropic (LLM), and ElevenLabs (voice) act as our sub-processors and may transfer data outside the EU under their own Standard Contractual Clauses or equivalent safeguards.
Where Personal Data of EU, UK, or Swiss users is transferred to the United States, such transfers are currently made in reliance on Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable) or other lawful transfer mechanisms. Once Borko LLC’s self-certification under the EU-U.S. Data Privacy Framework, the UK Extension, and the Swiss-U.S. DPF is finalized, transfers may additionally be made in reliance on those frameworks, as described in the “EU-U.S. Data Privacy Framework” section above.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at oriontaraban.ai@protonmail.com.
Users in the European Union, the United Kingdom, and Switzerland may also contact our Representative, Prighter, at https://app.prighter.com/portal/18075508469.