Privacy Policy

This Policy applies to the Zihin web platform and the Zihin AI mobile app (iOS), through which end users of customer organizations chat with AI agents. Zihin acts in two distinct roles when processing personal data:

1.1. As Controller. For personal data of tenant administrators and operators (name, e-mail, password hash, billing, platform usage telemetry), Zihin is the Controller and determines the purposes and means of processing.

1.2. As Processor. For personal data that the Customer (tenant) processes through the platform — including message content, the Customer's end-customer data, data accessed via database connections, trigger and MCP payloads, and other data under the Customer's control and direction — Zihin acts as Processor. The Customer is the Controller of such data and is responsible for the legal basis and purpose of processing. Zihin's obligations in this capacity are detailed in the DPA attached to the Terms of Use.

2.1. Registration and account data:

• Administrator's full name
• Corporate e-mail
• Password hash
• Billing information (via Stripe; we do not store card data directly)
• Tenant identification

2.2. Technical and usage data:

• IP address, browser, user agent
• Platform usage telemetry
• API call logs
• Token consumption and cost metrics
• Response times and provider selection
• Error and diagnostic events

2.3. Content submitted for AI processing:

• Prompts and instructions
• Attached files
• Conversation history
• Model-generated outputs
• Data returned from configured connections and MCPs

2.4. Data processed by the Zihin AI mobile app (iOS):

• Name, e-mail, and user and organization (tenant) identifiers
• Content of conversations with agents
• Voice notes recorded with the microphone
• Photos taken with the camera or chosen from the photo library
• Files the user attaches

This data is processed solely to provide the service (app functionality) and is linked to the user's account. The app only requests access to the microphone, camera, or photo library when the user chooses to record a voice note or attach a photo or file. The app does not use the data for tracking or advertising and does not collect the user's location.

App accounts are provisioned by the customer organization's administrator; the app does not offer account creation or deletion.

For the items in sections 2.3 and 2.4, processing occurs in the capacity of Processor, under the Customer's direction.

Zihin uses data to:

• Provide the platform and its features
• Route requests to AI providers selected by the Customer
• Operate routing between AI providers and the fallback mechanism, using operational metrics such as response time, error rate, and token consumption
• Prevent fraud, abuse, and security threats
• Monitor performance and stability
• Process payments and manage subscriptions
• Communicate about the account, updates, and support
• Comply with legal and tax obligations

Model training. Zihin does not train or fine-tune its own models on users' conversations, voice notes, photos, or files. Content is forwarded to the AI providers listed in section 4 only to generate the requested response.

Protection by AI providers. Zihin uses these providers under each provider's commercial API terms and data processing agreements (DPA). These terms require the same or equal protection of personal data as this Policy provides: confidentiality, security, use only to generate the response, and limited retention. Under these terms, content sent through the API is not used to train the providers' models.

Zihin does not sell personal data under any circumstances.

AI providers used. The list of providers is closed: OpenAI, Anthropic, Google, and xAI (Grok), plus OpenRouter, a model aggregator used only when the Customer configures its own access key, in which case the request is forwarded to the provider of the model chosen by the Customer. Voice note transcription is performed by OpenAI. Changes to this list will be reflected in this Policy.

Protection by AI providers. Zihin uses these providers under each provider's commercial API terms and data processing agreements (DPA). These terms require the same or equal protection of personal data as this Policy provides: confidentiality, security, use only to generate the response, and limited retention. Under these terms, content sent through the API is not used to train the providers' models.

Consent. In addition to the acceptance by the customer organization's administrator, the mobile app shows each user, on first access, a consent screen stating what data is sent (text, voice notes and their transcription, photos, files, and the conversation history), to whom (the servers of Zihin AI, Inc. and the AI providers listed above), and for what purpose (only to generate responses). The app then asks for the user's permission (Allow / Don't allow). Without permission, nothing is sent and the user is signed out. The user can review and withdraw the permission at any time in Profile → Data & AI.

When the Customer or user makes a request, the following is forwarded to the LLM provider selected by the Customer:

• Prompt and input content, including attached voice notes, images, and files
• System instructions (when configured)
• Conversation history (when applicable)

The following is not shared with providers:

• Administrator's e-mail or personal identification
• The Customer's API key
• Billing information
• Usage history of other tenant requests
• Data from other tenants

Each request is processed in isolation. Providers receive only the content strictly necessary to generate the response.

Zihin processes personal data based on:

• Contract performance: to provide the contracted services
• Legitimate interest: to improve the service, prevent fraud, and ensure security
• Legal obligation: to comply with tax, accounting, regulatory, and judicial requirements
• Consent: for optional communications and analytics, where required

The Customer may withdraw consent for optional processing at any time, upon request.

Zihin shares data, strictly to the extent necessary, with:

• AI providers: OpenAI, Anthropic, Google, xAI, and OpenRouter (the latter only with the Customer's own key), as described in section 4
• Payment processor: Stripe
• Infrastructure and hosting: Railway (hosting of the site and chat), Supabase (authentication, database, and storage), or equivalent providers
• Analytics and monitoring: internal and/or third-party tools, on an aggregated and anonymized basis whenever possible
• Aionz Integração Serviços e Tecnologia Ltda: when the Customer contracts professional services in Brazil (item 3.2 of the Terms)
• Accredited integration partners: when the Customer contracts professional services via channel (item 3.3 of the Terms)
• Legal authorities: when required by law, court order, or to protect the rights of Zihin or third parties

Data processing agreements are maintained with key suppliers. Zihin never shares personal data for advertising purposes.

Data may be processed in:

• United States (Zihin AI Inc. headquarters and primary infrastructure)
• European Union (selected providers and regions)
• Brazil (operations via Aionz)
• Other geographies, depending on LLM providers and infrastructure

Zihin observes GDPR and LGPD requirements for international transfers, including standard contractual clauses (SCC) and equivalent mechanisms where applicable.

• API request logs: 30 days (configurable for enterprise)
• Error logs: 90 days
• Usage analytics (aggregated): 12 months
• Billing records: 7 years (legal requirement)
• Account data: until deletion + 30-day grace period
• Webhook events: 90 days
• Conversations (sessions and messages) and attachments (voice notes, photos, and files): kept while the account or organization is active, or until deletion is requested from the organization's administrator or at contact@zihin.ai (the app has no account or data deletion function). The expiry of a conversation's resume window does not delete its content.
• Persistent agent memory (when enabled by the Customer): expires automatically after 30 to 180 days, depending on the category of the information

After the retention periods set out above, data is permanently deleted or anonymized.

The use of cookies is governed by our Cookie Policy, which forms part of this Privacy Policy.

Under LGPD, GDPR, and analogous regulations, data subjects have the right to:

• Access: receive a copy of the personal data processed
• Correction: update inaccurate or outdated data
• Deletion: request erasure ("right to be forgotten")
• Portability: receive data in a structured, interoperable format
• Restriction: limit types of processing
• Objection: object to certain processing
• Information: know with whom data is shared

Access, correction, and deletion in the mobile app. Zihin AI app accounts are provisioned by the customer organization's administrator, and the app has no account or data deletion function. To access, correct, or delete your data, send the request to your organization's administrator or to contact@zihin.ai.

Requests must be sent to contact@zihin.ai. Zihin responds within 30 days and may request identity verification. For data where Zihin acts as Processor, data subject requests should be directed primarily to the Customer (Controller), with Zihin's technical support where applicable.

Zihin adopts reasonable technical and organizational measures to protect personal data, including:

• Encryption in transit (TLS) and at rest for sensitive data
• Password hashing
• Multi-tenant segregation
• Role-based access control
• Audit logs
• Continuous monitoring

No system is completely immune to risk. In the event of a security incident involving personal data, Zihin will notify affected Customers in accordance with applicable legal requirements and the DPA procedures.

Zihin is not intended for individuals under 18 years of age. The platform must not be used to process minors' data without a specific legal basis and adequate supervision by the Customer.

• E-mail: contact@zihin.ai
• Data Protection Officer / DPO: contact@zihin.ai
• Address: Zihin AI Inc., 651 N Broad St, Suite 206, Middletown, DE 19709, USA
• Representative in Brazil (LGPD): Aionz Integração Serviços e Tecnologia Ltda, CNPJ 52.400.922/0001-90, Anápolis/GO, via e-mail contact@zihin.ai

Zihin may update this Policy periodically. Material changes will be communicated at least 14 days in advance via e-mail or dashboard notification.