ARAI Personal Data Processing Policy

CODEALIVE LTD (England and Wales, Company Number 16517721, address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom). Service: ARAI, arai.build. Personal data contact: support@arai.build.

Processing is automated. ARAI's infrastructure (the main database and file storage) is hosted by Amazon Web Services; processing by external providers is described in section 3.

Account, request and subscription data are necessary to perform the contract with you; financial transaction information may also be processed to meet applicable accounting and tax obligations. Access protection, abuse prevention and dispute resolution serve the controller's legitimate interests, subject to respect for your rights. Where applicable law requires consent, particularly for the cross-border transfers described below, it is requested separately. ARAI news is sent only with separate consent (see “Letters from ARAI” below). Withdrawal of consent does not end processing for which an independent applicable legal basis remains.

A problem report in chat may include an image of the part of the conversation visible to you. You can remove it before sending. We forward it with the report to the operator’s Telegram chat to investigate the problem. In ARAI the image is retained for the same period as the report: for signed-in users until account deletion, and for guests for 12 months after receipt, allowing any pending delivery to finish; it may be deleted earlier on request to support@arai.build. In Telegram it remains until the operator deletes it.

After data has actually been deleted from the live system, its copies in ordinary backups are destroyed within 14 days. This does not mean that every deletion request automatically destroys financial history or a pending task. Individual records without an automatic deletion period are reviewed on a request for restriction or deletion; convenience of storage alone does not override applicable retention and data-minimisation requirements.

Audio recordings are not used for voice identification. ARAI does not request an Individual Identification Number (IIN) or copies of identity documents for ordinary registration. Full card numbers, CVVs and bank codes are entered in the secure Stripe/Link checkout form, rather than in ARAI chat; ARAI does not store them. However, the payment and subscription history listed above is data that is processed. Do not include third parties' personal data in messages or files.

### Letters from ARAI

If you have provided and verified a contact email address, we may write to you when something has not worked for you in the Service, to help resolve the problem and achieve your intended result: for example, to let you know that we have fixed an error that prevented a task from being completed and suggest trying again. These letters are sent on behalf of ARAI’s founder and drafted with the help of artificial intelligence using information about your work in the Service. They are sent only when there is a specific reason and contain no advertising. Letters are enabled by default on the basis of the controller’s legitimate interest in ensuring that the Service works for you. You can turn them off in your account settings or through the link in any email. Replies are read by the ARAI team.

We send ARAI news — new features and articles, no more than twice a month — only with your separate consent. You select “ARAI news” in your account settings and confirm the subscription through the link in the email. You can withdraw consent at any time in your account settings or through the link in any email; withdrawal does not affect the lawfulness of sending before withdrawal.

Emails are sent through Amazon Simple Email Service (section 3).

Disclosure to third parties depends on the feature used and is described below. Account data is hosted in ARAI's infrastructure at Amazon Web Services and may be stored and processed outside your country. The workplace from the profile is not included in requests to external models; full name, language and time zone may be included to perform the task and address the User. Data you include yourself in messages, files or the checkout form may be transferred with them.

When setting up and servicing payments, Stripe and, for Managed Payments transactions, Link receive data from their checkout form, purchase information, country, and technical browser and connection information. They process data, including outside your country (a cross-border transfer), for payment processing, tax calculation, fraud prevention, receipts, refunds and disputes under their own terms and policies: https://stripe.com/privacy and https://link.com/privacy. They may act as independent data controllers for these purposes. ARAI receives verified transaction-status information and the necessary identifiers, but not the full card number or CVV. The presence of Stripe Sandbox does not mean that payment data will automatically be transferred to live payment mode.

Amazon Simple Email Service (Amazon Web Services) is used to verify the provided email address and send notifications provided for by the Service: the recipient address, the relevant notification content, delivery identifiers and results are processed, including outside your country (a cross-border transfer). AWS policy: https://aws.amazon.com/privacy/. Delivery rejection and complaints may result in sending to the address being stopped. Technical delivery records are not used for advertising mailings, and verifying an email address does not in itself constitute consent to advertising.

ARAI records authoritative server-side facts about sign-in, requests, responses and file handling in its journal in ARAI’s infrastructure at Amazon Web Services. These records contain no question or answer texts, phone numbers, full names, file names, full page URLs or access links. They retain the account identifier where available, without a separate browser visitor identifier or referral-source attribution. They continue to be recorded for operation, accounting and security regardless of the browser statistics choice. The retired browser collector and reporting system no longer receive new records; existing records remain subject to their retention schedule and account-deletion rights.

PostHog Inc. (PostHog Cloud EU, Frankfurt, Germany), a data processor that may be located outside your country, is also used for analysis: https://posthog.com/privacy. It receives statistics on views and actions, browser and device information, the IP address to determine the country, and masked website session recordings. Sessions are not recorded in the iOS app. Input fields, chat messages, uploaded-file information, results, profile and payment areas are masked or blocked; reviewed welcome controls remain visible. Chat text, file names, CAD content, phone numbers, full names, e-mail and ARAI cookies are not sent to PostHog. URL fragments and query parameters are removed except for eight campaign parameters: utm_source, utm_medium, utm_campaign, utm_content, utm_term, gclid, yclid and fbclid. Share-link tokens and private referrer paths are removed. After sign-in, a pseudonymous account identifier is used. The server forwards account-linked usage facts, language, account country, plan, creation date and an internal/test account flag regardless of the browser statistics choice; that choice governs browser collection only. Guest server facts are not forwarded. For LLM analysis, only numerical usage metrics and technical identifiers are sent: model and provider, tokens including cached tokens, cost, latency and an error flag, without requests, responses or file content. Primary account, operation and expense records remain in ARAI's database at Amazon Web Services. PostHog retention follows its project settings and differs from the primary journal. Deleting an ARAI account does not yet automatically delete its PostHog person or already collected analytics; contact support@arai.build to request deletion. Automatic PostHog deletion remains pending implementation.

On the arai.build homepage, the Yandex Metrica counter (YANDEX LLC, Russia) is loaded only for visitors whose country is determined from their network IP address to be Armenia (AM), Azerbaijan (AZ), Belarus (BY), Kazakhstan (KZ), Kyrgyzstan (KG), Moldova (MD), Russia (RU), Tajikistan (TJ), Turkmenistan (TM) or Uzbekistan (UZ), and only after separate permission for advertising measurement. An unknown country is not eligible; the interface language does not replace this check. It uses cookies and processes views, goals, referral source, device and browser information, and IP addresses on Yandex servers, including outside your country (a cross-border transfer), under the terms at https://yandex.ru/legal/confidential. Session recording, the click map and recording of form fields are disabled in the installed code. This counter is not installed in chat, in the account or on any other pages.

ARAI browser statistics (PostHog, including masked website session recordings) are enabled by default; Yandex advertising analytics is disabled by default. A saved statistics refusal is respected, including when saved together with the advertising choice; browser statistics are not collected when choice storage is unavailable. Each category can be changed in the Optional analytics section on this page or in your account without restricting sign-in, use or payment. The arai_measurement cookie stores the choice and its time for 180 days without a person identifier; iOS stores the choice locally. There is no blocking banner. Withdrawal stops new optional browser collection and clears accessible PostHog identifiers; requests already dispatched may complete. It does not automatically erase previously collected data. Contact support@arai.build for deletion requests. Cookies on third-party domains that ARAI cannot access can be removed through the browser.

Sign-in codes are delivered through the Telegram messenger (Telegram FZ-LLC, UAE): you provide your number to the ARAI bot yourself using the “Share phone number” button, after which Telegram processes the number, your Telegram account identifier and sign-in code messages on its servers, including outside your country (a cross-border transfer), under its own terms. This transfer takes place with your consent.

The contents of your messages, uploaded files, dictated audio recordings and search queries—without the phone number or workplace from your profile—are transferred for processing to third-party artificial intelligence, search and file-conversion providers that may be located outside your country, including in countries that do not ensure personal data protection; if you include personal data in this content, it will be transferred with it. This transfer takes place with your consent. To address you, models also receive the full name from your profile, language and time zone. OpenRouter also receives a stable account or session identifier to prevent abuse. It is sent separately from the message text.

ARAI processes audio during the request and does not retain it in its own file storage. Speech recognition providers may retain it under their own terms. Soniox receives the uploaded recording; after processing, ARAI requests deletion of the recording and transcript, but immediate deletion is not guaranteed if the provider is unavailable or returns an error.

Engineering tasks are performed by the ARAI agent in an isolated virtual machine in ARAI's infrastructure. Files and conversation text, information about your previous tasks, the full name from your profile, language and time zone are transferred to the machine for the task. The agent uses OpenAI models through ARAI's account, so task materials read by the agent while performing the task are transferred to OpenAI, including outside your country (a cross-border transfer), and processed under its terms. Results are returned to chat. To allow the task to be continued and revised, its checkpoints and results are retained in ARAI's storage until account deletion; deleting the conversation does not delete them. The agent's working notes about your work are stored separately for each account, transferred only to tasks belonging to that account, and deleted with the account. Before a task, clarification or answer to the agent is accepted, the request text is automatically screened by a third-party provider's AI model, including outside your country (a cross-border transfer): it assesses whether the request seeks to obtain ARAI's internal materials. ARAI does not store the request text in the screening record: it stores only the screening result, score, category and time, until account deletion.

If you click “Share conversation”, the conversation text up to and including the selected response becomes available to anyone with the link. Publishing a subsequent response extends the content available through the same link. Attachments and tool results are not published, but personal data included in messages remains in the published text. Closing the system sharing window does not revoke the link. You can revoke it under “Account → My public links” or by deleting the conversation or account; copies already saved by recipients cannot be retrieved.

The service is provided using an artificial intelligence system: responses are texts generated by an AI system, may contain errors and do not replace the official texts of regulatory documents. The service does not make decisions with legal effects for you on the basis of automated processing.

You may request access to your personal data and information about its processing, require its correction, blocking or deletion, and withdraw consent. Conversations can be deleted through the interface. For accounts without payment history, a deletion request is available in the account; physical deletion takes place after tasks have safely finished and associated storage has been cleared. If the account has payment history or the interface does not accept a deletion request, send it to support@arai.build: automatic deletion of such accounts is not yet available. This technical limitation does not remove your rights; requests are reviewed individually, separating necessary financial records from data that must be deleted. Deleting an account does not replace cancellation of subscription renewal.

Send requests and complaints to support@arai.build. We respond within the periods required by applicable law and explain the legal basis, scope and duration of any refusal or restriction of deletion. Proportionate information may be required to verify your entitlement to make the request; do not send your password, sign-in code or card details. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal; features dependent on that consent may become unavailable.

If the UK GDPR applies, you also have rights to restriction of processing, objection to processing and data portability, subject to the conditions established by that law. You may complain to the UK Information Commissioner's Office (ICO): https://ico.org.uk/make-a-complaint/. You may also contact the competent data protection authority in your country, including Kazakhstan's authorised personal data protection authority where applicable. Nothing in this policy restricts other rights under mandatory provisions of applicable law.