Privacy Policy

Last Updated: Sept 2, 2025

1. Introduction

Hugogen ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Cortex Reasoning Model services ("Service"). Please read this Privacy Policy carefully.

By accessing or using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, do not use our Service.

2. Information We Collect

2.1 Information You Provide to Us

We collect information that you voluntarily provide when using our Service, including:

  • Account information (name, email address, password, phone number)
  • Profile information (job title, company name, preferences)
  • Payment information (processed by third-party payment processors)
  • Content you submit (prompts, queries, documents, files, data)
  • Communications with us (emails, support tickets, feedback)
  • Survey responses and research participation data

2.2 Automatically Collected Information

When you access our Service, we automatically collect certain information, including:

  • Device information (IP address, browser type, operating system, device identifiers)
  • Usage information (pages viewed, features used, time spent, click patterns)
  • Log data (access times, error logs, referral URLs)
  • Location information (general geographic location based on IP address)
  • Cookies and similar tracking technologies (see Section 8)

2.3 AI Interaction Data

We collect data about your interactions with our AI models, including:

  • Input prompts and queries you submit
  • AI-generated responses and outputs
  • Feedback on AI responses (ratings, corrections, reports)
  • Conversation history and context
  • Model performance metrics and error data

3. How We Use Your Information

We use the information we collect for the following purposes:

  • Providing the Service: To operate, maintain, and provide features of our AI platform
  • Model Training and Improvement: To train, fine-tune, evaluate, and improve our AI models and algorithms
  • Personalization: To customize your experience and provide personalized recommendations
  • Communication: To send you updates, security alerts, and administrative messages
  • Support: To respond to your inquiries and provide customer support
  • Analytics: To analyze usage patterns and improve Service performance
  • Security: To detect, prevent, and address fraud, security issues, and technical problems
  • Legal Compliance: To comply with legal obligations and protect our rights
  • Research and Development: To conduct research and develop new features and services
  • Marketing: To send promotional communications (with your consent where required)

4. AI Model Training and Data Usage

Important: By default, your content and interactions may be used to train and improve our AI models.

We use your data for model training in the following ways:

  • Training data for improving model accuracy and capabilities
  • Fine-tuning models for specific domains or tasks
  • Evaluating model performance and identifying failure modes
  • Developing new AI features and capabilities
  • Creating aggregated or anonymized datasets for research

Before using your data for training, we may:

  • Remove or redact personally identifiable information
  • Aggregate data with other users' data
  • Apply data minimization and anonymization techniques
  • Filter out sensitive or inappropriate content

You may have the option to opt out of having your data used for model training by adjusting your account settings or contacting us. However, opting out may limit certain features or capabilities.

5. How We Share Your Information

We may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

  • Cloud hosting and infrastructure providers
  • Payment processors and billing services
  • Analytics and monitoring services
  • Customer support platforms
  • Email and communication services
  • Security and fraud prevention services

5.2 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction.

5.3 Legal Requirements

We may disclose your information if required by law or in response to valid requests by public authorities, including:

  • Compliance with legal obligations
  • Response to subpoenas, court orders, or legal processes
  • Protection of our rights, property, or safety
  • Investigation of fraud or security issues
  • Enforcement of our Terms of Service

5.4 With Your Consent

We may share your information for any other purpose with your consent.

6. Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary based on data type:

  • Account Information: Retained while your account is active and for a reasonable period thereafter
  • Content and Inputs: May be retained indefinitely for model training and improvement purposes
  • Usage Data: Typically retained for 12-24 months
  • Log Data: Generally retained for 90-180 days
  • Training Data: May be retained indefinitely in anonymized or aggregated form

When we no longer need your information, we will securely delete or anonymize it. However, we may retain anonymized or aggregated data indefinitely for research and analytical purposes.

7. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction, including:

  • Encryption of data in transit and at rest
  • Regular security assessments and audits
  • Access controls and authentication mechanisms
  • Employee training on data protection
  • Incident response and breach notification procedures
  • Network security and monitoring

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security.

8. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities. These technologies help us:

  • Remember your preferences and settings
  • Authenticate your identity
  • Analyze Service usage and performance
  • Provide personalized content and features
  • Improve security and prevent fraud

Types of cookies we use:

  • Essential Cookies: Required for Service functionality
  • Analytics Cookies: Help us understand usage patterns
  • Functional Cookies: Remember your preferences
  • Advertising Cookies: May be used for targeted advertising

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of the Service.

9. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

  • Access: Request access to your personal information
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your information
  • Portability: Request a copy of your information in a portable format
  • Objection: Object to processing of your information
  • Restriction: Request restriction of processing
  • Opt-Out: Opt out of model training and marketing communications
  • Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, please contact us at [email protected]. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

Please note that certain information may be exempt from such requests under applicable law. We may also need to verify your identity before processing your request.

10. International Data Transfers

Your information may be transferred to, and processed in, countries other than your country of residence. These countries may have data protection laws that differ from the laws of your country.

When we transfer personal information from the European Economic Area (EEA), United Kingdom, or Switzerland, we implement appropriate safeguards, such as:

  • Standard Contractual Clauses approved by the EU Commission
  • Adequacy decisions by relevant authorities
  • Other legally recognized transfer mechanisms

By using our Service, you consent to the transfer of your information to the United States and other countries where we or our service providers operate.

11. Children's Privacy

Our Service is not intended for children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children under these ages.

If we learn that we have collected personal information from a child under the applicable age without parental consent, we will take steps to delete that information as soon as possible. If you believe we have collected information from a child, please contact us at [email protected].

12. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

  • Right to know what personal information we collect, use, disclose, and sell
  • Right to delete personal information (subject to certain exceptions)
  • Right to opt out of the sale of personal information
  • Right to non-discrimination for exercising your privacy rights

Note: We do not sell personal information as defined by the CCPA. However, we may share information with service providers and for model training purposes as described in this Privacy Policy.

To exercise your California privacy rights, contact us at [email protected] or call us at [phone number].

13. European Privacy Rights (GDPR)

If you are located in the EEA, UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

  • Legal basis for processing your information
  • Right to access and receive a copy of your data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing (including for direct marketing)
  • Right to withdraw consent at any time (where processing is based on consent)
  • Right to lodge a complaint with a supervisory authority

Our legal bases for processing include: performance of a contract, legitimate interests, consent, and legal obligations.

14. Third-Party Links and Services

Our Service may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party services you access.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

  • Posting the new Privacy Policy on this page
  • Updating the "Last Updated" date
  • Sending you an email notification (for material changes)
  • Displaying a notice on our Service

Your continued use of the Service after we post modifications constitutes your acceptance of the updated Privacy Policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Hugogen

Email: [email protected]

By using our Service, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.