Privacy Policy

Last updated: 23 April 2026

Introduction

This Privacy Policy explains how Prodigy AI Solutions (“we”, “us”, “our”) collects and uses personal data when you visit our websites/documentation, purchase our products through cloud marketplaces, or contact us. It also explains how we process data when our retrieval infrastructure layer / framework (the “Service”) is used by our business customers.

We are committed to processing personal data in line with the EU General Data Protection Regulation (GDPR – Regulation (EU) 2016/679).

Scope

This policy covers our websites, documentation, and customer communications related to Verbis Graph Engine and our Service. It does not cover external websites we link to.

1) Who we are

If you are an end user using the Service via one of our customers (for example, your employer or another organization), that customer may be the primary controller for the data they upload and process through the Service (see Section 2).

2) Roles: when we are Controller vs Processor

Because our Service is used by businesses, our role can vary depending on context:

If you are a customer and need a Data Processing Addendum (DPA), contact us at ab@verbisgraph.com.

3) What personal data we collect

The data we collect depends on how you interact with us.

A) Website, documentation, and communications

B) Marketplace purchase and subscription data (AWS Marketplace / Microsoft Commercial Marketplace)

If you subscribe via AWS Marketplace or Microsoft Commercial Marketplace (including Azure Marketplace/AppSource), the marketplace may provide us data needed to provision and manage your subscription, such as:

Payment details: in most cases, payment details are processed by the marketplace provider under its own terms and privacy policy, not directly by us.

C) Service telemetry and logs

To operate and secure the Service, we may process:

We do not store document snippets or customer document content in logs as a normal practice. If a customer’s configuration or troubleshooting workflow could cause limited content to appear in diagnostics, we aim to minimize it and handle it securely.

D) Customer Content (as Processor)

Depending on the customer’s usage, Customer Content may include personal data (for example, names inside documents). Typical categories can include:

Customers control what they upload and must ensure they have appropriate rights and legal bases to process that content.

4) Why we use personal data (purposes) and legal bases

We process personal data only when we have a lawful basis.

A) To provide and administer the Service (Contract / Legitimate Interests)

Legal basis: performance of a contract (GDPR Art. 6(1)(b)) and/or legitimate interests (Art. 6(1)(f)).

B) To secure, maintain, and improve the Service (Legitimate Interests / Legal Obligation)

Legal basis: legitimate interests (Art. 6(1)(f)); legal obligation where applicable (Art. 6(1)(c)).

C) Sales and B2B marketing (Legitimate Interests / Consent where required)

Legal basis: legitimate interests (Art. 6(1)(f)) and/or consent (Art. 6(1)(a)) where required by law. You can opt out of marketing at any time (see Section 11).

D) Compliance, accounting, and legal claims (Legal Obligation / Legitimate Interests)

Legal basis: legal obligation (Art. 6(1)(c)) and/or legitimate interests (Art. 6(1)(f)).

5) AI / model training promise

We do not train AI models on customer datasets

We do not use Customer Content (including datasets, documents, embeddings/vectors, or queries) to train our general AI models or foundation models.

If you enable a third-party integration (for example, sending prompts or content to an external AI provider), that third party’s processing is governed by their own terms and privacy policy, and the customer is responsible for configuring those integrations.

6) Who we share personal data with

We do not sell or rent personal data.

We may share personal data only as needed with:

A) Cloud marketplaces

AWS and Microsoft act as independent parties for marketplace operations under their own privacy policies. We receive limited data needed to provision and support subscriptions (see Section 3B).

B) Service providers (processors/sub-processors)

We use trusted vendors to operate our business and the Service. We may share data with providers in categories such as:

We require appropriate contractual safeguards and confidentiality obligations. Sub-processors list: we do not publish a public list here. We can provide the current list to customers under a DPA and/or upon request at ab@verbisgraph.com.

C) Legal and safety disclosures

We may disclose information where required by law, regulation, or legal process, or to protect rights, safety, and security.

D) Business transfers

If we are involved in a merger, acquisition, financing, or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate safeguards.

If you subscribe via AWS Marketplace or Microsoft Commercial Marketplace, the marketplace may share limited subscription and administrative contact information with Prodigy AI Solutions so we can provision and support your subscription. Payment details are handled by the marketplace provider under its own privacy policy. Prodigy AI Solutions does not train AI/foundation models on customer datasets or Customer Content.

7) International transfers

We are established in the EU (Italy). If we transfer personal data outside the European Economic Area (EEA), we apply appropriate safeguards such as:

plus additional technical measures when appropriate (e.g., encryption, access controls).

8) Data retention

We keep personal data only as long as needed for the purposes in this policy, then delete or anonymize it, unless a longer retention is required by law.

Below is a practical retention schedule:

9) Security

We apply appropriate technical and organizational measures to protect personal data, which may include:

No system is perfectly secure, but we work to prevent unauthorized access, disclosure, alteration, or loss.

10) Cookies and similar technologies

Our websites and documentation may use cookies or similar technologies for essential functionality, preferences, analytics (where enabled), and (optional) marketing (where enabled). Where required, we show a cookie banner and allow you to manage preferences. You can also control cookies through your browser settings.

For details on cookies, categories, and controls, see our Cookie Policy.

11) Your rights under GDPR

If GDPR applies, you may have the right to:

How to exercise your rights

Email us at ab@verbisgraph.com. We may ask for reasonable verification to protect you from unauthorized requests.

If you are an end user of a customer

If your data is processed through a customer’s use of the Service (Customer Content), the customer is typically the controller. Please contact that customer first. We will assist the customer as required under our DPA.

Supervisory authority

If you are in Italy, you can lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority) or your local EU authority.

12) Children

Our Service is intended for business/professional use and is not directed to children. We do not knowingly collect personal data from children.

13) Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will publish updates on this page and change the “Last updated” date. If changes are material, we may provide additional notice (for example, via email to account administrators or through product notices).

14) Contact

For privacy questions or requests:

For details on cookies, categories, and controls, see our Cookie Policy.

𐦂𖨆𐀪𖠋 Follow Us to See Our Progress