Privacy Policy

Sudennian AI is a research company that works to create reliable, interpretable and orientable AI systems to assist develop games.

This Privacy Policy explains how we collect, use, disclose, and process your personal data when you use our website and other places where Sudennian AI may act as a data controller and link to this Privacy Policy—for example, when you interact with ArchLevel.ai or other products as a consumer for personal use ("Services").

This Privacy Policy also describes your privacy rights. More information about your rights, and how to exercise them, is set out in the “Rights and Choices” section.

1. Collection of Personal Data

We collect the following categories of personal data:

Personal data you provide to us directly

Identity and Contact Data: Sudennian AI collects identifiers, such as your name, email address, and phone number when you sign up for an Sudennian AI account, or to receive information on our Services. We may also collect indirect identifiers (e.g., “USER12345”).
Payment Information: We may collect your payment information if you choose to purchase access to Sudennian AI’s products and services.
Inputs and Outputs: Our AI services allow you to prompt the Services in a variety of media including but not limited to the format of text, files and documents, photos and images, and other materials along with the metadata and other information contained therein (“Prompts” or "Inputs"), which generate responses (“Outputs” or “Completions”) based on your Inputs. If you include personal data in your Inputs, we will collect that information and this information may be reproduced in your Outputs.
Feedback on your use of our Services: We appreciate feedback, including ideas and suggestions for improvement or rating an Output in response to an Input. If you rate an Output in response to an Input—for example, by using the thumbs up/thumbs down icon—we will store the related conversation as part of your Feedback.
Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send.

Personal data we receive automatically from your use of the Services

When you use the Services, we also receive certain technical data automatically (described below, collectively “Technical Information”). This includes:

Device and Connection Information. Consistent with your device or browser permissions, your device or browser automatically sends us information about when and how you install, access, or use our Services. This includes information such as your device type, operating system information, browser information and web page referers, mobile network, connection information, mobile operator or internet service provider (ISP), time zone setting, IP address (including information about the location of the device derived from your IP address), identifiers (including device or advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers).
Usage Information. We collect information about your use of the Services, such as the dates and times of access, browsing history, search, information about the links you click, pages you view, and other information about how you use the Services, and technology on the devices you use to access the Services.
Log and Troubleshooting Information. We collect information about how our Services are performing when you use them. This information includes log files. If you or your device experiences an error, we may collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
Cookies & Similar Technologies. We and our service providers use cookies, scripts, or similar technologies (“cookies”) to manage the Services and to collect information about you and your use of the Services. These technologies help us to recognize you, customize or personalize your experience, market additional products or services to you, and analyze the use of our Services to make it more useful to you. For more details about how we use these technologies, and your opt-out controls and other options, please visit our Cookie Policy.

Personal data we receive indirectly to train our models

Sudennian AI obtains personal data from third party sources in order to train our models. We take steps to minimize the privacy impact on individuals through the training process. Learn more here.

2. Uses of Personal Data and our Legal Bases under European data protection laws

We will only use your personal data when the law allows us to. Usually, we rely on the following grounds under European data protection laws (our “Legal Bases”):

Where we need it to perform a contract with you. For example, we process Identity and Contact Data, Inputs, Outputs and Payment Information in order to provide Services to you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override our interests. Our legitimate interests include:
- providing, maintaining and improving our products and services;
- research and developing, including developing new products and features;
- marketing our products and services;
- detecting, preventing and enforcing violations of our terms including misuse of services, fraud, abuse, and other trust and safety protocols; and
- protecting our rights and the rights of others.
Where you have given us your consent. You have the right to withdraw your consent at any time.
Where we need to comply with our legal obligations.

We will not use your Inputs or Outputs to train our models, unless: (1) your conversations are flagged for Trust & Safety review (in which case we may use or analyze them to improve our ability to detect and enforce our Acceptable Use Policy, including training models for use by our Trust and Safety team, consistent with Sudennian AI’s safety mission), or (2) you’ve explicitly reported the materials to us (for example via our feedback mechanisms), or (3) by otherwise explicitly opting in to training.

We use your personal data for the following purposes:

3. How We Disclose Personal Data

Sudennian AI will disclose personal data to the following categories of third parties for the purposes explained in this Policy:

Affiliates & corporate partners. Sudennian AI discloses the categories of personal data described above between and among its affiliates and related entities.
Service providers & business partners. Sudennian AI may disclose the categories of personal data described above with service providers and business partners for a variety of business purposes, including website and data hosting, ensuring compliance with industry standards, research, auditing, and data processing.

Sudennian AI may also disclose personal data in the following circumstances:

As part of a significant corporate event. If Sudennian AI is involved in a merger, corporate transaction, bankruptcy, or other situation involving the transfer of business assets, Sudennian AI will disclose your personal data as part of these corporate transactions.
Third-Party Websites and Services: Our Services may involve integrations with, or may direct you to, websites, apps, and services managed by third parties. By interacting with these third parties, you are providing information directly to the third party and not Sudennian AI and subject to the third party’s privacy policy.
If you access third-party services, such as social media sites or other sites linked through the Services (e.g., if you follow a link to our Twitter account), these third-party services will be able to collect personal data about you, including information about your activity on the Services. If we link to a site or service via our Services, you should read their data usage policies or other documentation. Our linking to another site or service doesn’t mean we endorse it or speak for that third party.
To comply with regulatory or legal requirements, safety and to enforce our terms. We may disclose personal data to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations. We may also disclose personal data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or any other person, to protect against fraud or credit risk, or to enforce our legal rights or contractual commitments that you have made.
With an individuals’ consent. Sudennian AI will otherwise disclose personal data when an individual gives us permission or directs us to disclose this information.

4. Rights and Choices

Subject to applicable law and depending on where you reside, you may have some rights regarding your personal data, as described further below. Sudennian AI will not discriminate based on the exercising of privacy rights you may have.

To exercise your rights, you or an authorized agent may submit a request by emailing us at privacy@sudennian.com. After we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may also have the right to appeal requests that we deny by emailing privacy@sudennian.com.

Right to know. You may have the right to know what personal data Sudennian AI processes about you, including the categories of personal data, the categories of sources from which it is collected, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it.
Access & data portability. You may have the right to request a copy of the personal data Sudennian AI processes about you, subject to certain exceptions. In certain cases and subject to applicable law, you have the right to port your information.
Deletion. You may have the right to request that we delete personal data collected from you and retained, subject to certain exceptions. Learn more here.
Correction. You may have the right to request that we correct inaccurate personal data Sudennian AI retains about you, subject to certain exceptions. Please note that we cannot guarantee the factual accuracy of Outputs. If Outputs contain factually inaccurate personal data relating to you, you can submit a correction request and we will make a reasonable effort to correct this information—but due to the technical complexity of our large language models, it may not always be possible for us to do so.
Objection. You may have a right to object to processing of your personal data, including profiling conducted on grounds of public or legitimate interest. We will no longer process the personal data in case of such objection unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims. If we use your information for direct marketing, you can object and opt out of future direct marketing messages using the unsubscribe link in such communications.
Restriction. You have the right to restrict our processing of your personal data in certain circumstances.
Withdrawal of consent. Where Sudennian AI’s processing of your personal data is based on consent, per the table in Section 2 above, you have the right to withdraw your consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Automated decision-making: Sudennian AI does not engage in decision making based solely on automated processing or profiling in a manner which produces a legal effect (i.e., impacts your legal rights) or significantly affects you in a similar way (e.g., significantly affects your financial circumstances or ability to access essential goods or services).
Sale & targeted Sudennian AI marketing of its products and services. Sudennian AI does not “sell” your personal data as that term is defined by applicable laws and regulations. If we share your personal data for targeted advertising to promote our products and services in the future, you can opt-out and we will honor global privacy controls. To learn more, click here.

5. Data Transfers

When you access our website or Services, your personal data may be transferred to our servers in the US, or to other countries outside the European Economic Area (“EEA”) and the UK. This may be a direct provision of your personal data to us, or a transfer that we or a third party make (the latter being a “Transfer”).

Where information is transferred outside the EEA or the UK, we ensure it benefits from an adequate level of data protection by relying on:

Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country outside of the EEA offers an adequate level of data protection. We transfer your information as described in “Collection of Personal Data” to some countries with adequacy decisions, such as the countries listed here; or
Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information as described in “Collection of Personal Data” to certain affiliates and third parties in countries without an adequacy decision.

In certain situations, we rely on derogations provided for under applicable data protection law to transfer information to a third country.

6. Data Retention and Data Lifecycle

Sudennian AI retains your personal data for as long as reasonably necessary for the purposes and criteria outlined in this Privacy Policy and explained further in our support center.

Aggregated or De-Identified Information

We may process personal data in an aggregated or de-identified form to analyze the effectiveness of our Services, conduct research, study user behavior, and train our AI models. For instance:

When you submit Feedback and provide us permission, we disassociate Inputs and Outputs from your user ID to use them for training and improving our models.
If our systems flag Inputs or Outputs for potentially violating our Acceptable Use Policy, we disassociate the content from your user ID to train our trust and safety classification models and internal generative models. However, we may re-identify the materials to enforce our Acceptable Use Policy with the responsible user if necessary.
To improve user experience, we may analyze and aggregate general user behavior and usage data. This information does not identify individual users.

7. Children

Our Services are not directed towards, and we do not knowingly collect, sell, or share any information about, children under the age of 18. If you become aware that a child under the age of 18 has provided any personal data to us while using our Services, please email us at privacy@sudennian.com and we will investigate the matter and, if appropriate, delete the personal data.

8. Changes to Our Privacy Policy

Sudennian AI may update this Privacy Policy from time to time. We will notify you of any material changes to this Privacy Policy, as appropriate, and update the Effective Date at the top of https://www.sudennian.com/privacy-policy. We encourage you to review that page for updates when you access the Services.

9. Contact Information

The data controller responsible for your personal data is Sudennian AI PBC. If you have any questions about this Privacy Policy, or have any questions, complaints or requests regarding your personal data, you can contact us as described below:

Sudennian AI .Inc Objective of incorporating a C-corp Austin, TX (United States). [Future physical locations Q2 2024]
Sudennian AI Incorporate the parent organization of a PBC in Delaware (United States). [Future physical locations Q2 2024]
Sudennian AI Limited Objective of incorporation in London, UK (United Kingdom). [Future physical locations Q2 2024]

You can email us at privacy@sudennian.com.

Please note that you have the right to lodge a complaint with the supervisory authority in the EU country in which you live or work. A full list of EU supervisory authorities’ contact details is available here. If you live or work in the UK, you have the right to lodge a complaint with the UK Information Commissioner’s Office.

10. When This Privacy Policy Applies

This Privacy Policy does not apply where Sudennian AI acts as a data processor and processes personal data on behalf of commercial customers of Sudennian AI’s AI services, unless otherwise specified in this Privacy Policy. In those cases, the commercial customer is the controller, and you can review their privacy policy for more information about how they handle your personal data.

You can find information on our Subprocessor List about the third parties Sudennian AI engages to help us process personal data provided to us where Sudennian AI acts as a data processor, such as with respect to personal data we receive, process, store, or host when you use Sudennian AI's AI services as or through a commercial customer.

Purpose Type of Data Legal Basis

To provide and facilitate the Services with you with respect to your Sudennian AI account, which are governed by our Terms of Service

• Identity and Contact Data

• Payment Information

• Feedback

• Contract

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To communicate with you for non-marketing purposes including by sending you Services-related emails, push notifications, and other messages

• Identity and Contact Data

• Communication Information

• Contract

To create and administer your Sudennian AI account

______________________________________________________________________________________________________________

• Identity and Contact Data

• Payment Information

• Feedback

• Contract

To facilitate payments for products and services provided by Sudennian AI

• Identity and Contact Data

• Payment Information

• Contract

______________________________________________________________________________________________________________

To prevent and investigate fraud, unlawful or criminal activity, unauthorized access to or use of personal data or Sudennian AI systems and networks, and to meet governmental and institutional policy obligations

• Identity and Contact Data

• Payment Information

• Inputs and Outputs

• Technical Information

• Legitimate interests
• Legal obligation
It is our legitimate interest to protect our business, employees and users from illegal activities, inappropriate behavior or violations of terms that would be detrimental. We also have a duty to cooperate with authorities.

______________________________________________________________________________________________________________

To investigate and resolve disputes

• Identity and Contact Data

• Inputs and Outputs

• Feedback

• Legitimate interests
• Legal obligationIt
It is our legitimate interest to fully understand and make reasonable efforts to resolve customer complaints in order to improve user satisfaction. We also have a legal obligation in some cases.

To investigate and resolve security issues

• Identity and Contact Data

• Payment Information

• Technical Information

• Legal obligation
• Legitimate interests
It is our legitimate interest to protect user data and our systems from intrusion or compromise through monitoring and swift response. We also have a legal obligation to provide adequate security safeguards.

To send you marketing communications, where you have signed up to receive them

• Identity and Contact Data

• Consent

______________________________________________________________________________________________________________

To debug and to identify and repair errors that impair existing functionality

• Identity and Contact Data

• Payment Information

• Technical Information

• Legitimate interests
It is our legitimate interest to maintain continuous functioning of our services and rapid correction of problems to ensure a positive user experience that encourages engagement.

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To improve the Services and conduct research

• Identity and Contact Data

• Payment Information

• Technical Information

• Legitimate interests
It is our legitimate interest and in the interest of Sudennian AI users to evaluate the use of the Services and adoption of new features to inform the development of future features and improve direction and development of the Services.

______________________________________________________________________________________________________________

To de-identify it and train our AI models

• Inputs and Outputs

• Feedback

• Technical Information

• Legitimate interests
It is our legitimate interest to utilize de-identified data to improve our AI models. This enables us to provide more accurate and helpful services over time based on real-world usage.

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To enforce our Terms of Service and similar terms and agreements, including our Acceptable Use Policy.

• Identity and Contact Data

• Inputs and Outputs

• Technical Information

• Contract
In certain circumstances outside of the performance of our contract with you, we may rely on legitimate interests.
It is our legitimate interest to enforce the rules and policies governing use of our services, to maintain intended functionality and value for users. We aim to provide a safe, useful platform.

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