Chavy

CHAVY.AI PLATFORM PRIVACY POLICY

Effective Date:

1. INTRODUCTION AND SCOPE

This Privacy Policy explains how Chavy.ai ("we", "us", "our") collects, uses, discloses, and safeguards your personal data when you visit our marketplace and use our platform services (the "Platform"). This Policy applies to all users, including Clients seeking services and third-party Developers offering software or freelance services. This document is designed to comply with global data protection frameworks, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA).

2. DELINEATION OF ROLES: CONTROLLER VS. THIRD-PARTY PROCESSOR

It is critical to understand the separation of data responsibilities on our hybrid platform:

Chavy.ai as Data Controller: We act as the Data Controller (or "Business" under the CCPA) strictly concerning the administrative information provided to create an account, navigate the marketplace, facilitate billing for platform access, and utilize internal messaging.

Developer as Data Controller/Processor: When a Client engages a third-party Developer for freelance services or utilizes a Developer's Outcome-as-a-Service (OaaS) software, the Developer acts as an independent Data Controller, or as a direct Data Processor to the Client.

Disclaimer: Chavy.ai and the third-party Developers do not jointly determine the purposes of processing operational data. We explicitly disclaim all liability under the GDPR, CCPA, or otherwise, for data processing activities, algorithmic operations, server configurations, or data breaches occurring within the Developer's OaaS environment or personal infrastructure.

3. INFORMATION WE COLLECT

We collect the following categories of information exclusively to operate the marketplace:

  • Identity and Contact Data: First and last name, email address, physical address, phone number, and corporate registration details provided during account creation.
  • Financial and Transaction Data: Billing addresses and limited payment details. Primary payment processing is handled by compliant third-party payment gateways; Chavy.ai does not store full credit card numbers or raw banking data on our servers.
  • Technical and Usage Data: IP addresses, browser types, operating systems, session lengths, time zone settings, and platform interaction metrics collected via tracking technologies.
  • Profile and Vetting Data (Developers): Resumes, portfolios, identification documents for Know Your Customer (KYC) compliance, and the results of our initial onboarding technical assessments.

4. LEGAL BASIS FOR PROCESSING (GDPR COMPLIANCE)

We process personal data based on the following lawful bases:

  • Contractual Necessity: To provide marketplace access, manage accounts, and facilitate matchmaking and payments.
  • Legitimate Interests: To ensure platform security, prevent fraud, perform onboarding vetting, enforce our Terms of Service, and improve matchmaking algorithms.
  • Legal Obligation: To comply with tax, Anti-Money Laundering (AML), and accounting laws.
  • Consent: To deploy non-essential cookies and send direct marketing communications. You may withdraw consent at any time.

5. INFORMATION SHARING AND DISCLOSURE

Chavy.ai does not "sell" your personal data to third parties. We share data strictly under the following circumstances:

  • Platform Facilitation: When a Client engages a Developer, we share basic profile and contact information to facilitate the transaction. Upon initiation, the Developer becomes legally responsible for that data.
  • Service Providers: We share data with trusted third-party partners (e.g., identity verification services, cloud hosting, customer support tools, payment processors) bound by strict Data Processing Agreements.
  • Corporate Restructuring: In the event of a merger, acquisition, or sale of assets, user data may be transferred to the acquiring entity.
  • Legal Compliance: We may disclose data to regulatory authorities or law enforcement if required to do so by law, subpoena, or court order.

6. OAAS AND FREELANCE EXCHANGE DATA DISCLAIMER

Clients utilizing OaaS software or engaging freelance talent frequently upload proprietary data, source code, customer databases, or personal information directly to the Developer's hosted environment, software applications, or via APIs. This operational data flows directly from the Client to the Developer. Chavy.ai does not host, view, process, or store this operational data. Clients are solely responsible for executing appropriate Data Processing Agreements (DPAs) or Non-Disclosure Agreements (NDAs) directly with the Developer. Chavy.ai is not liable for data compromises occurring within the Developer's sphere of control.

7. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, and similar tracking technologies to enhance user experience, analyze platform traffic, and manage sessions. You can control cookie preferences through your browser settings. Declining essential cookies may limit your ability to use certain features of the Platform.

8. INTERNATIONAL DATA TRANSFERS

Chavy.ai operates globally. Personal data may be transferred to, stored, and processed in jurisdictions outside the European Economic Area (EEA), including the United States and the jurisdiction of our incorporation. We ensure appropriate safeguards are implemented, such as the European Commission's Standard Contractual Clauses (SCCs), to guarantee that data remains protected according to strict EU standards regardless of geographic location.

9. DATA RETENTION AND SECURITY

We implement commercially reasonable, industry-standard technical and organizational measures (including TLS encryption and role-based access controls) to secure platform data. However, no digital environment is entirely secure. Users utilize the platform at their own risk. We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy, or as legally required to comply with statutory retention periods.

10. YOUR DATA SUBJECT RIGHTS

Depending on your jurisdiction of residence (e.g., EU, UK, California), you have specific rights regarding the administrative data Chavy.ai controls:

  • Right to Access/Know: Request copies of the specific personal data we hold.
  • Right to Deletion/Erasure: Request deletion of your data (subject to legal AML/tax retention exceptions).
  • Right to Rectification: Request correction of inaccurate data.
  • Right to Opt-Out: Opt-out of the sharing of data for cross-context behavioral advertising.
  • Right to Non-Discrimination: You will not face adverse treatment for exercising your privacy rights.

Note: If you wish to exercise data rights concerning information processed by an OaaS software or a third-party Developer, you must submit that request directly to the respective Developer.

11. CHILDREN'S PRIVACY

The Chavy.ai Platform is designed strictly for adult professionals and B2B transactions. It is not intended for anyone under the age of 18. We do not knowingly collect data from minors. If we become aware that we have collected such data, we will delete it immediately.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. In accordance with P2B Regulations and consumer protection standards, material changes will be communicated via email and a prominent platform notice at least fifteen (15) days prior to their effective date.

13. CONTACT INFORMATION

If you have questions about this Privacy Policy, your data rights, or how we handle your information, please contact our Data Protection Officer at:

Email: [email protected]