PRIVACY POLICY
Last updated January 15, 2025

1. INTRODUCTION

This Privacy Notice for Foxtery S.L. ("we", "us", or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Visit our website at http://www.foxtery.com, or any website of ours that links to this Privacy Notice

  • Use our AI-powered corporate learning platform that enables continuous knowledge transfer and learning within organizations

  • Engage with us in other related ways, including any sales, marketing, or events

This Privacy Notice is part of our broader framework for protecting personal data, along with our Data Processing Agreement (DPA) and Terms of Service. The DPA is specifically designed for Corporate Customers (organizations) and sets out detailed obligations, liabilities, and security measures for handling data on behalf of those organizations. This Privacy Notice, by contrast, provides a high-level overview of how we handle personal information across our Services as a whole.

Throughout this Privacy Notice, we refer to:

  • "Corporate Customer" as any organization that has entered into an agreement with us to use our Services (as further defined in our Terms of Service and/or DPA).

  • "End User" as any individual who accesses or uses our Services through a Corporate Customer's account, often employees, contractors, or authorized personnel within that organization.

Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@foxtery.com.

Key Terms and Definitions:

  • "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular individual or household.

  • "AI-Generated Content" refers to any content, including but not limited to courses, tests, materials, and assessments, that is automatically generated by our Service using artificial intelligence technologies.

  • "Learning Data" means any information related to user interaction with educational content, including progress, completion rates, assessment results, and performance metrics.

  • "Platform" refers to our AI-powered learning management system and all related features and services.

  • "Corporate Customer" means any organization that has entered into an agreement with us to use our Services.

  • "End User" means any individual who accesses or uses our Services through a Corporate Customer's account.

Scope of This Privacy Policy:

This Privacy Policy applies to all personal information processed by us through our Services, regardless of the way it is collected or processed. This includes:

  1. Customer Account Information: Data provided during account creation and management

  2. Learning Platform Data: Information collected during the use of our educational services

  3. AI Processing Data: Information processed by our artificial intelligence features

  4. Technical Data: Automatically collected information about service usage

  5. Communication Data: Information exchanged through our support and communication channels

This Privacy Policy should be read in conjunction with our Terms of Service and Data Processing Agreement (DPA). For Corporate Customers, additional terms regarding data processing may be specified in your service agreement with us.


2. SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find more details about any of these topics by using our table of contents below to find the section you are looking for.

Personal Information Processing

When you use our Services, we process personal information based on your interactions with our platform and the features you use. This includes account and profile information, learning activity data, AI-generated content interactions, and technical usage information. You can learn more about the specific types of personal information we collect in the detailed sections below.

Use of Your Information

We process your information primarily to provide and maintain our AI-powered learning platform, generate and customize educational content, track learning progress and performance, ensure platform security and effectiveness, and comply with our legal obligations. The specific details about how we process your information are available in the dedicated section of this Privacy Notice.

Legal Basis for Processing

Our processing of your personal information is based on valid legal grounds under applicable law. We only process data when necessary, such as with your consent, to comply with laws, to provide you with services, or to pursue legitimate business interests. All processing activities are conducted in accordance with applicable data protection regulations.

AI and Learning Platform Features

Our service incorporates AI-powered features for generating personalized learning content, analyzing learning patterns, providing adaptive recommendations, and processing corporate training materials. All AI processing adheres to strict data protection regulations and our comprehensive security standards.

Data Security and Corporate Protection

We maintain robust security measures to protect your data, including isolated environments for each corporate customer, end-to-end encryption for sensitive information, regular security audits, and strict access controls. Our security practices are designed to ensure the highest level of data protection while maintaining service effectiveness.

Your Rights and Choices

Your privacy rights vary depending on your location and applicable laws. These may include the right to access or delete your data, correct inaccurate information, opt out of AI processing, and request data portability. You can exercise these rights through our privacy dashboard, by contacting our Data Protection Officer, or through your account settings.

Policy Updates and Contact Information

We maintain this notice to reflect changes in our services and ensure compliance with relevant laws. Material changes will be communicated through our platform or via email. For any questions about this notice, you can contact our Data Protection Officer at Foxtery S.L., Calle Marc Aureli 10, Barcelona, Barcelona 08006, Spain, or by email at dpo@foxtery.com.


3. INFORMATION WE COLLECT

In Short: We collect personal information that you provide to us, information automatically collected when you use our Services, and information specifically related to learning activities and AI interactions.

Personal Information You Provide

We collect personal information that you voluntarily provide to us when you register for the Services, express interest in obtaining information about us or our products and Services, or otherwise when you contact us.

The personal information we collect depends on your interactions with us and the Services, your choices, and the products and features you use. This personal information may include names, email addresses, job titles, usernames, passwords, billing addresses, and contact or authentication data.

For payment processing, we may collect necessary data such as your payment instrument number and security code. All payment data is processed and stored by Stripe. Their privacy practices can be reviewed at https://stripe.com/privacy.

If you choose to register using your existing social media account details, we may collect certain profile information stored in your social media platform account.

Learning-Related Information

As an AI-powered learning platform, we collect information about your educational activities and progress. This includes course participation data, completion records, assessment results, and interaction with learning materials. We process this information to track progress, generate certificates, and provide personalized learning experiences.

When corporate customers upload training materials for AI processing, we collect and process this content to generate educational materials and assessments. This may include corporate documentation, training guidelines, and learning objectives.

Automatically Collected Information

We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal your specific identity but may include device and usage information, IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and technical information about how you interact with our Services.

We primarily use this information to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy at https://foxtery.com/policies/cookie-policy.

The information we collect includes device data such as your computer, phone, tablet, or other device specifications, operating system details, unique device identifiers, and browser type. We also collect location data based on your IP address, which can be either precise or imprecise depending on your device settings and permissions.

Usage and Learning Analytics Data

Our platform automatically collects data about how users interact with learning content and AI-generated materials. This includes time spent on different learning modules, interaction patterns, completion rates, and assessment performance. This information helps us improve our Services and provide more effective learning experiences.

We want to emphasize that all learning-related data is processed in isolated environments for each corporate customer, ensuring data separation and security. We do not combine or share learning analytics between different corporate customers.

Third-Party Information

We do not collect information from third parties except when you choose to register using social media accounts or when specifically authorized by your organization for corporate training purposes. Our use of information received from Google APIs adheres to Google API Services User Data Policy, including the Limited Use requirements.


4. HOW WE USE YOUR INFORMATION

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

Purpose and Legal Basis

We use the information we collect or receive for providing and maintaining our AI-powered learning platform. Your personal information enables us to create and manage user accounts, deliver our Services, and ensure proper platform functionality. This processing is necessary for performing our contractual obligations to you and pursuing our legitimate business interests.

Learning Platform Operations

For our core learning management functionality, we process your information to track educational progress, generate performance analytics, and provide personalized learning experiences. This includes analyzing completion rates, assessment results, and learning patterns to improve educational effectiveness. We maintain strict data isolation between corporate customers to ensure confidentiality of organizational learning data.

AI-Enhanced Learning

We utilize AI technology to enhance the learning experience on our platform. This includes basic content analysis and personalization of learning paths. For detailed information about our AI processing capabilities and safeguards, please refer to section 7 "AI AND LMS SPECIFIC PROCESSING".

Service Administration and Communication

We process your information to send administrative information, including updates about our terms, conditions, and policies. We may also use your information to respond to your inquiries, provide customer support, and maintain the security of our platform. When you contact us, we maintain records of your communication to help solve any issues you might have.

Platform Analytics and Improvement

We analyze platform usage patterns to improve our Services and develop new features. This analysis is conducted using aggregated and anonymized data to protect user privacy. Our analytics help us understand how users interact with the platform and identify areas for improvement, while maintaining strict data protection standards.

Marketing Communications

With your consent, we may process your information for marketing purposes, including sending you information about our products and services. You can opt out of marketing communications at any time while continuing to receive essential service-related messages.

Legal Compliance and Protection

We may process your information to respond to legal requests, prevent fraud, and maintain security. This includes:

  • Identity verification

  • Fraud prevention

  • Response to legal requirements

  • Security audit logging

  • Regulatory compliance

All processing activities comply with applicable data protection laws and are protected by appropriate security measures. We do not sell your personal information or use it for any purpose other than those described in this Privacy Notice.


5. LEGAL BASES FOR PROCESSING

In Short: We only process your personal information when we believe it is necessary and have a valid legal basis under applicable law, such as with your consent, to comply with laws, to provide you with services, or to fulfill our legitimate business interests.

Consent-Based Processing

We may process your information if you have given us permission. You can withdraw your consent at any time through your account settings or by contacting us. However, this will not affect any processing conducted while your consent was in place. For AI-powered features, we obtain specific consent for using your data to generate and personalize learning content.

Contractual Obligations

We process your information when we believe it is necessary to fulfill our contractual obligations to you. This includes providing access to our learning platform, generating AI-powered educational content, and maintaining essential service functionality. For corporate customers, this also covers the processing required to deliver agreed-upon learning management services.

Legitimate Business Interests

We may process your information where we believe it is necessary for our legitimate business interests, provided these interests do not outweigh your rights and freedoms. This includes improving our Services, developing new features, and ensuring platform security. We carefully assess the potential impact on your privacy before relying on legitimate interests as a legal basis.

Legal Obligations

In some cases, we may process your information where we believe it is necessary for compliance with our legal obligations, such as responding to legal requests from authorities or maintaining required business records. This may include retaining certain learning completion records to comply with educational or professional certification requirements.

Vital Interests

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party. This processing ground is reserved for truly essential circumstances and is not used for routine operations.

Geographic Considerations

If you are located in the European Economic Area (EEA) or United Kingdom, GDPR requirements govern our data processing activities. Similar protections apply for users in other jurisdictions with comprehensive data protection laws. For international data transfers, we maintain appropriate safeguards such as Standard Contractual Clauses.

Your data protection rights may vary depending on your location. We are committed to respecting these rights and providing you with appropriate control over your information. For specific information about the rights available in your jurisdiction, please refer to the "Your Rights" section of this Privacy Notice.


6. INFORMATION SHARING AND DISCLOSURE

In Short: We share information with third parties only when necessary to provide our Services, comply with legal obligations, protect rights, or fulfill business obligations.

Service Providers and Technology Partners

We carefully select and regularly audit service providers that help us operate our platform. Our infrastructure relies on trusted cloud hosting services for platform operations, secure payment processors for financial transactions, and specialized analytics services for performance monitoring.

For our AI-powered features, we work with several key technology partners. OpenAI provides natural language processing capabilities for content generation. Microsoft Azure AI powers our learning pattern analysis and personalization features, and NVIDIA AI supports the computational processing for our AI models.

These providers operate data centers across multiple regions, with primary processing for EU customers occurring within the European Union. Additional facilities in the United States handle secondary processing and global services, while Asia Pacific infrastructure supports global operations. Each technology partner undergoes a rigorous selection process, including security and privacy compliance audits, data protection capability assessment, regular performance reviews, and establishment of strong contractual safeguards for data protection.

Corporate Data Protection

We maintain strict data isolation between different organizations using our platform. Your company's data environment is completely separated from other customers. This isolation encompasses all aspects of your data, including learning content, training materials, user activity records, progress data, AI-generated content, analytics, and administrative settings. Each corporate environment operates independently to ensure maximum data protection.

Business Transfers

In the event of a merger, acquisition, or asset sale, your information may be transferred as part of that transaction. We will notify you of any ownership changes and maintain existing privacy protections throughout the process. Any acquiring entity will be contractually bound to honor our privacy commitments, and we will ensure you have options for data export or deletion.

Legal Requirements and Rights Protection

There may be circumstances where we need to share information in response to legal requirements or to protect rights. This includes responding to valid legal requests from authorities, investigating potential policy violations, preventing fraud or abuse, and protecting individual safety. All such disclosures are carefully reviewed by our legal team, limited to the minimum necessary information, and protected by appropriate confidentiality measures.

Data Aggregation and Research

We may use aggregated and anonymized data for platform improvement, industry research, and service optimization purposes. This aggregated data is processed using strict anonymization protocols that prevent identification of individual users or organizations. The process excludes specific organizational content and ensures the resulting data cannot be linked back to any individual or entity. This type of anonymized, aggregate data is not considered personal data under privacy laws.

We emphasize that we never sell personal information to third parties. All data sharing is conducted solely for specified purposes under appropriate safeguards, with a focus on maintaining the privacy and security of your information.


7. AI AND LMS SPECIFIC PROCESSING

In Short: Our platform utilizes artificial intelligence and learning management systems to provide educational services, requiring specific data processing protocols to ensure security and effectiveness.

AI Content Generation and Processing

Our AI-powered learning platform processes organizational content to create comprehensive educational materials. The system generates various types of content, including structured courses with theoretical and practical modules, knowledge assessment tests, skill evaluation exercises, interactive learning materials, and adaptive quizzes. Each type of content is tailored to specific learning objectives and organizational requirements.

The content generation process follows several stages. Initially, the system analyzes your corporate training materials, documentation, and learning objectives. It then creates preliminary content drafts, which undergo automated quality checks for accuracy, relevance, and alignment with learning goals. Each piece of generated content passes through multiple validation steps, including consistency verification, language quality assessment, and learning objective alignment validation.

Our platform offers extensive customization options for AI-generated content. Organizations can define specific terminology requirements, set preferred content structures, specify assessment formats, and establish custom validation rules. The system adapts to your organization's training methodology and can be configured to match your specific pedagogical approaches.

Every piece of AI-generated content remains exclusively within your organization's environment, with strict controls preventing any cross-contamination between different corporate customers. The AI models process each customer's data independently, ensuring complete privacy of proprietary information.

Learning Management Processing

Our learning management system comprehensively tracks educational progress and performance to provide meaningful insights and improve learning outcomes. The system processes completion rates, assessment results, time spent on modules, and interaction patterns, storing all data securely within your organization's isolated environment.

From this data, the system generates detailed progress reports, completion certificates, and performance analytics. These insights help identify learning trends and areas for improvement while maintaining individual privacy and organizational confidentiality.

Content Ownership and Rights

All AI-generated content created from your organization's materials belongs exclusively to your organization. This ownership extends to all generated materials, including courses, assessments, learning materials, and any derivative content. We maintain clear boundaries of ownership and ensure your intellectual property rights are protected throughout the entire generation process.

Data Training and Model Improvement

To enhance our AI capabilities, we may use anonymized and aggregated learning patterns to improve our models. This process never includes specific content from your organization or personally identifiable information. We maintain complete transparency about this process, and organizations can opt out of contributing to model improvements while retaining full access to all platform features.


8. DATA SECURITY

In Short: We prioritize the protection of your personal information through robust security measures and continuous monitoring.

Security Infrastructure and Practices

We have implemented technical and organizational security measures aligned with recognized industry best practices. Our infrastructure incorporates multiple layers of protection, with security controls regularly validated through independent assessments. We use advanced encryption for data in transit (TLS 1.3) and at rest (AES-256), alongside secure key management.

For our AI-powered learning platform, we maintain isolated processing environments for each corporate customer. This design ensures complete data separation, with dedicated processing resources and encryption keys for each organization. We also deploy threat detection systems and real-time monitoring to protect our AI environments from unauthorized access.

International Data Protection

We meet relevant data transfer regulations by implementing safeguards that meet or exceed standard requirements. Our primary data processing is located in Germany, with secondary facilities in the United States. Where appropriate, we rely on contractual mechanisms such as Standard Contractual Clauses to facilitate compliant cross-border data flows. We periodically review and update our documentation of data transfers to ensure alignment with evolving regulatory standards.

Access Controls and Monitoring

We enforce role-based access controls that limit access to customer data to authorized personnel only. All access attempts are logged and monitored for suspicious activities, triggering alerts for immediate investigation if anomalies arise. Our team members undergo background checks, and we reinforce secure development and operational practices through regular training.

Security Assessment and Auditing

We conduct comprehensive security assessments on a defined schedule, including:

  • Automated vulnerability scans

  • Penetration testing by external specialists

  • Internal policy audits and reviews

Any findings are documented and remediated according to established risk severity levels, ensuring our infrastructure and systems remain resilient against emerging threats.

Incident Response and Recovery

While no system is entirely immune to security incidents, we maintain a documented incident response process covering identification, containment, eradication, and recovery. Our incident response team operates with defined escalation paths, and in the event of a confirmed data breach, we notify affected users and relevant authorities within required legal timeframes, providing transparent impact assessments and mitigation steps.

Employee Security Management

All employees receive security awareness training during onboarding, with periodic refresh sessions. Those involved in handling sensitive data or AI systems undergo specialized instruction in threat recognition, secure handling, and incident response. We maintain a security-first culture with regular exercises and ongoing awareness initiatives to foster proactive risk management.

Data Storage and Business Continuity

Our primary data centers are located in Germany, with secondary facilities in the United States. Both locations feature stringent physical security measures, continuous environmental monitoring, real-time data replication, and encrypted backups. We regularly test documented recovery procedures to ensure swift operational restoration in the event of disruptions, maintaining the integrity and confidentiality of your data.


9. YOUR RIGHTS AND CHOICES

In Short: Depending on your location, you have certain rights regarding your personal information. We provide tools and settings to help you control your privacy. We may extend our response time for complex requests, and we encourage direct contact with our DPO for any concerns.

Your Data Protection Rights

You have the right to access, update, or delete your information. This includes viewing the personal data we hold about you, correcting any inaccuracies, and requesting deletion of your information. For our learning platform users, this extends to accessing your learning history, assessment results, and AI-generated content specific to your account.

The specific rights available to you depend on your location. Users in the European Economic Area, United Kingdom, and similar jurisdictions have comprehensive rights under applicable data protection laws. These include the right to data portability, the right to restrict processing, and the right to object to processing.

Extension of Response Time

We strive to respond to valid privacy requests within 30 days. However, under GDPR and similar regulations, we can extend this period by up to two additional months when requests are complex or numerous. In such cases, we will inform you of the extension and the reason for the delay within the initial 30-day period.

DPO and Request Process

To exercise your privacy rights, please contact our Data Protection Officer at dpo@foxtery.com. For verification purposes, we may request additional information to confirm your identity before processing your request. This helps ensure we share information only with authorized individuals. If you are an End User under a Corporate Customer, we may also coordinate with your organization to fulfill the request appropriately, in line with our Data Processing Agreement.

Control Over AI Processing

You maintain control over how your information is used in our AI systems. This includes the ability to opt out of certain AI-powered features while continuing to use core platform functionality. Corporate Customers can specify how their training materials are processed by our AI systems and manage the retention of AI-generated content.

Managing Your Preferences

You can update your account preferences and privacy settings through our platform interface. This includes controlling email notifications, adjusting learning tracking preferences, and specifying how your data is used. For marketing communications, you can opt out at any time while continuing to receive essential service-related messages.

Appeal Process

If you believe your privacy rights request has not been adequately addressed, you can appeal our decision by contacting our Data Protection Officer. You also have the right to lodge a complaint with your local data protection authority if you are unsatisfied with our response.


10. INTERNATIONAL DATA TRANSFERS

In Short: We process and store your information in Germany and the United States, and maintain appropriate safeguards for international data transfers. We also offer data residency options for Corporate Customers to help meet local regulatory requirements.

Data Storage Locations

Your information is primarily stored and processed in our secure data centers located in Germany and the United States. We choose these locations to ensure optimal service performance and maintain compliance with international data protection standards. Our German data center serves as our primary facility for European operations, while our US facility supports our global service delivery.

Data Residency Options

We understand that some Corporate Customers may have specific regulatory or internal policy requirements about where their data is stored. To address this, we offer data residency options that allow organizations to choose the region in which their learning content and personal data are processed. If your jurisdiction requires data to remain within certain geographic boundaries, we will work with you to ensure compliance and proper configuration of data location settings.

Transfer Safeguards

When we transfer data between countries, we implement appropriate safeguards to protect your information. For transfers from the European Economic Area (EEA), we rely on European Commission-approved Standard Contractual Clauses, alongside supplementary technical and organizational measures. These legal mechanisms ensure that your data receives consistent protection regardless of where it is processed.

Corporate Data Protection

For our corporate customers, any cross-border data flows strictly adhere to the terms of our Data Processing Agreement and your organization's policies. We maintain robust documentation of all data flows to confirm compliance with applicable data protection laws in different jurisdictions.

Service Provider Transfers

Some of our service providers, particularly our AI technology partners, may process data in various global locations. We carefully select these providers and ensure they maintain appropriate data protection standards through contractual commitments and regular assessments. Whenever third-party processing occurs outside your chosen data residency region, we apply equivalent safeguards and continuously monitor compliance.

Transparency and Control

We maintain transparency about where your data is stored and processed. You can contact our Data Protection Officer for specific information about data locations, transfer mechanisms, or to discuss your organization's data residency preferences. If local regulations in your jurisdiction impose additional requirements, we will work with you to implement those measures and document compliance.


11. DATA RETENTION

In Short: We keep your information for as long as necessary to provide our Services, comply with legal obligations, and fulfill the purposes outlined in this Privacy Notice.

Core Retention Principles

We retain personal information only for as long as necessary to deliver our Services and fulfill the purposes described in this Privacy Notice. The specific retention period depends on the type of information, its purpose, and our legal obligations. After this period, we securely delete or anonymize your information.

Platform Data Retention

For our learning management platform, we maintain different retention periods based on data types. Account information remains active while you maintain a user account with us. Learning progress data and completion records are kept according to your organization's requirements and applicable educational standards.

AI-Generated Content

AI-generated learning content is retained as long as your organization maintains an active subscription to our Services. You can export or delete this content at any time through your account settings. When content is deleted, it is removed from our active systems and securely erased according to our data deletion protocols.

Post-Service Retention

After service termination, we maintain limited data for thirty days to allow for account recovery and data export. Following this period, your personal information is removed from our active systems. However, we may retain certain information in backup systems for a limited period or as required by law.

Legal and Compliance Requirements

Certain information must be retained to meet legal, tax, accounting, or regulatory requirements. For example, we maintain basic transaction records for financial reporting purposes. We also retain evidence of completed training and certifications as required by professional standards or compliance requirements.

Technical Limitations

Due to the nature of our backup and recovery systems, some information may remain in our secure backup systems after deletion from active systems. This data is securely stored, isolated from our active environment, and permanently deleted according to our backup rotation schedule.


12. CHILDREN'S PRIVACY

In Short: We do not knowingly collect data from or market to children under 18 years of age, but we recognize that local laws may set different age thresholds.

General Policy

Our Services are primarily intended for adult professionals. We do not knowingly collect, use, or disclose personal information from individuals under 18 years of age (or under the applicable minimum age in certain jurisdictions, which may be 16 or 13). All platform users must confirm they meet the minimum age requirement when creating an account.

Corporate Learning Environment

In cases where our platform is used for corporate training programs that include apprentices, interns, or other trainees under the legal age threshold, the Corporate Customer is responsible for obtaining necessary parental or guardian consent and ensuring compliance with relevant youth protection regulations. We require explicit confirmation from the Corporate Customer that such consents are in place before allowing access for underage participants.

Protective Measures

Our platform includes measures to prevent unauthorized youth access. During account creation, users must confirm they meet the applicable age requirement. If we discover that we have inadvertently collected information from someone under the minimum age, we will promptly delete such information from our systems and review our practices to prevent future occurrences.

Discovery and Deletion

If you believe we might have collected information from or about a child under the applicable minimum age, please contact our Data Protection Officer immediately at dpo@foxtery.com. Upon verification, we will take steps to delete such information and document the incident for compliance purposes.


13. UPDATES TO PRIVACY POLICY

In Short: We update this notice as necessary to stay compliant with relevant laws and reflect changes in our Services.

Policy Evolution

We regularly review and update this Privacy Notice to ensure it accurately reflects our practices, services, and legal requirements. As our AI-powered learning platform evolves and we introduce new features, we may need to update this notice to describe new data processing activities.

Notification of Changes

When we make material changes to this Privacy Notice, we will notify you through our platform interface or by sending you an email. Material changes include significant updates to how we process your personal information, use AI technologies, or share data with third parties.

Change Communication

For substantial updates, we provide advance notice before changes take effect. This gives you time to review the changes and understand how they might affect you. The notification will include a summary of significant changes and their effective date.

Prior Versions

When we update this Privacy Notice, the previous version remains accessible through our platform for reference. You can review these archived versions to understand how our practices have evolved. Corporate customers receive direct notifications about policy updates that might affect their organization's data processing.

Continued Use

Your continued use of our Services after changes to this Privacy Notice become effective constitutes acceptance of the updated terms. If you disagree with the changes, you should discontinue using our Services and contact us to discuss your concerns.


14. CONTACT INFORMATION

In Short: If you have questions or comments about this notice or your data protection rights, we encourage you to contact our Data Protection Officer (DPO). We also provide a dedicated Privacy Team for general inquiries.

Primary Contact

For any questions, comments, or concerns about this Privacy Notice or our data practices, please reach out to our Data Protection Officer:
Foxtery S.L.
Data Protection Officer
Calle Marc Aureli 10
Barcelona, Barcelona 08006
Spain
Email: dpo@foxtery.com
Phone: +34936940325
(Available Monday to Friday, 9:00-18:00 CET)

Privacy Team

For more general privacy-related inquiries or if you're unsure whether your request requires DPO review, you can contact our Privacy Team at privacy@foxtery.com. They handle initial triage, guide you on next steps, and can escalate complex cases to the DPO if needed.

Support Channels

For technical support or assistance with privacy-related features, you can reach us through:

Regulatory Inquiries

If your question concerns a specific regulation or jurisdiction, you can reach our compliance team at compliance@foxtery.com. EU residents also have the right to contact their local data protection authority regarding any unresolved privacy concerns.

Response Time

We strive to respond to all privacy-related inquiries within 30 days. For complex requests, we may require additional time (up to two more months) and will inform you of the reason for delay. Our team operates primarily in the CET time zone. We appreciate your patience and will keep you informed throughout the process.

Company Details

Foxtery S.L.
Registration No.: B16372799
VAT: ESB16372799
Director: Artem Maslov