PRIVACY POLICY

1. Overview

Varunos respects your privacy.

This Privacy Policy explains how we collect, use, store, and protect personal and organizational data when you use our Platform.

This policy applies to our websites, applications, and services (collectively, the “Platform”), and to interactions you have with us such as support requests, sales inquiries, and events.

If you use the Platform on behalf of an organization (for example, your employer or your company), that organization may control or administer your account, including access, role permissions, and settings.

2. Key Definitions

For clarity, we use the following terms in this policy:

• Personal Data: information that identifies or can reasonably be linked to an individual.
• Customer Content: operational data, documents, messages, and other information you or your organization uploads or inputs into the Platform.
• Usage Data: technical and interaction data generated when you use the Platform (such as log data and feature usage).
• Service Providers: vendors we use to help deliver the Platform (such as hosting, analytics, security, customer support, and AI providers).

3. Information We Collect

We collect information you provide directly, information generated through your use of the Platform, and information we may receive from integrations or service providers (for example, identity verification or payment processing where enabled).

a) Account Information

• Name
• Company name
• Email address
• Role/title
• Contact details

b) Billing & Transaction Information

• Billing address and payment-related metadata (as applicable)
• Subscription plan, invoices, and transaction history

Where enabled, payments are processed by Stripe. We do not store full payment card numbers on our servers.

c) Operational Data

• Vessel data
• Noon reports
• Emissions inputs
• Uploaded documents

d) Technical & Usage Data

• IP address
• Device/browser type
• Usage logs
• Interaction history

e) Support & Communications

• Messages you send to us (for example, emails and support tickets)
• Feedback, survey responses, and troubleshooting information you choose to share

4. How We Use Information

We use data to:

• Provide and improve our services
• Generate AI responses
• Perform analytics
• Maintain security
• Communicate with users

We may also use data to:

• Onboard accounts, authenticate users, and administer access controls
• Provide customer support and troubleshoot issues
• Send service messages (such as security or policy updates)
• Prevent fraud, abuse, and unauthorized access
• Comply with applicable law and enforce our terms

We do not sell user data.

Where applicable, we process personal data to provide the Platform and perform our contract with you, to comply with legal obligations, and for legitimate interests such as securing and improving the Platform. Where required, we rely on your consent (for example, for optional cookies).

5. AI Processing

Uploaded content and queries may be processed by:

• Cloud infrastructure providers
• AI model providers (e.g., OpenAI, Groq, or similar services)
• Search service providers (when regulatory updates are requested)

Data is processed solely for providing the Platform’s services.

We do not use Customer Content to train public AI models.

Depending on the feature, AI processing may include transforming or summarizing uploaded documents, retrieving relevant excerpts, and generating responses. AI outputs are generated automatically and may be incomplete, outdated, or inaccurate; you should independently verify decisions and compliance obligations.

6. Cookies, Analytics, and Similar Technologies

We may use cookies and similar technologies to operate the Platform, keep you signed in, remember preferences, measure performance, and understand feature usage.

Optional cookies (including analytics and marketing cookies) are used only with your consent. You can manage your preferences via Cookie Settings.

You can control cookies through your browser settings. If you disable cookies, some features may not work properly.

7. How We Share Information

We share information only as needed to operate the Platform and run our business. Examples include:

• Service Providers (hosting, analytics, security, customer support, email delivery, AI providers) who process data on our behalf
• Integrations and connected services you enable, where data is shared as part of the integration’s functionality
• Legal and safety, when we believe disclosure is necessary to comply with law, respond to lawful requests, protect rights and safety, or prevent fraud and abuse
• Business transfers, if we are involved in a merger, acquisition, financing, reorganization, or sale of assets (subject to appropriate safeguards)
• With your direction or consent, when you ask us to share information

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

8. Data Storage & Security

Data is stored in secure cloud infrastructure.

We implement:

• Access controls
• Encryption in transit
• Role-based access management
• Audit logging

We take reasonable steps to safeguard information.

No method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your credentials and for using appropriate security practices (such as strong passwords and multi-factor authentication where available).

9. Data Retention

We retain data:

• For the duration of the user’s account
• As required for operational or legal purposes

Users may request deletion of their data subject to legal retention requirements.

We may retain limited records (for example, audit logs, security logs, and billing records) to comply with legal obligations, resolve disputes, enforce agreements, and maintain the safety and integrity of the Platform.

10. Cross-Border Transfers

Data may be processed in jurisdictions outside Singapore depending on cloud provider infrastructure.

We take reasonable measures to ensure appropriate safeguards are in place.

11. Your Rights and Choices

Subject to applicable law, you may:

• Request access to your personal data
• Request correction of inaccurate data
• Request deletion where applicable
• Request a copy of certain personal data in a portable format (where applicable)
• Object to or restrict certain processing (where applicable)

Requests can be made to info@varunos.com. We may need to verify your identity before responding.

If your data is controlled by your organization (for example, an enterprise account), you may need to contact your account administrator to exercise certain rights.

12. Third-Party Services

We may use third-party providers for:

• Cloud hosting
• Payment processing
• AI model services
• Email communications

These providers are contractually bound to protect data.

The Platform may also include links to third-party sites or services. Their privacy practices are governed by their own policies.

13. Children’s Privacy

The Platform is intended for business use and is not directed to children. We do not knowingly collect personal data from children.

14. Updates

We may update this Privacy Policy from time to time.

Changes will be posted on this page with updated effective date.