Privacy Policy
Version 2.0 — Updated June 4, 2026
Platform controller: Zihin AI Inc., 651 N Broad St, Suite 206, Middletown, DE 19709, USA.
1. Overview and Roles under LGPD/GDPR
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. What We Collect (as Controller)
2.1. Registration and account data:
2.2. Technical and usage data:
2.3. Content submitted for AI processing:
For the items in section 2.3, processing occurs in the capacity of Processor, under the Customer's direction.
3. How We Use Your Data
Zihin uses data to:
Zihin does not sell personal data under any circumstances.
4. Sharing with AI Providers
When the Customer makes a request via the platform, the following is forwarded to the LLM provider selected by the Customer:
The following is not shared with providers:
Each request is processed in isolation. Providers receive only the content strictly necessary to generate the response.
5. Legal Basis for Processing
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.
6. Sharing with Sub-processors and Third Parties
Zihin shares data, strictly to the extent necessary, with:
• AI providers: OpenAI, Anthropic, Google, and others, as selected by the Customer for request processing
• Payment processor: Stripe
• Infrastructure and hosting: Vercel, Supabase, 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.
7. International Transfers
Data may be processed in:
Zihin observes GDPR and LGPD requirements for international transfers, including standard contractual clauses (SCC) and equivalent mechanisms where applicable.
8. Data Retention
• 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
After the retention periods, data is permanently deleted or anonymized.
9. Cookies
The use of cookies is governed by our Cookie Policy, which forms part of this Privacy Policy.
10. Data Subject Rights
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
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.
11. Security
Zihin adopts reasonable technical and organizational measures to protect personal data, including:
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.
12. Minors
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.
13. Data Protection Contact
14. Updates to this Policy
Zihin may update this Policy periodically. Material changes will be communicated at least 14 days in advance via e-mail or dashboard notification.