Privacy Policy

Effective Date: May 27, 2026

Asuna AI Inc. ("Asuna AI", "we", "us" or "our") offers an AI-powered image generation platform. This Privacy Policy describes how Asuna AI processes personal information collected through our website (asuna.ai), applications, and related services (collectively, the "Service"), as well as through marketing activities, events, and other described activities.

Asuna AI may provide additional or supplemental privacy policies for specific products or services at the time of collection.

NOTICE TO EUROPEAN USERS: See the Notice to European Users section for additional information for individuals in the European Economic Area or United Kingdom.

Index

  1. Personal Information We Collect
  2. How We Use Your Personal Information
  3. Retention
  4. How We Share Your Personal Information
  5. Your Choices
  6. Other Sites and Services
  7. Security
  8. International Data Transfers
  9. Children
  10. Changes to This Privacy Policy
  11. Notice to European Users
  12. How to Contact Us

1. Personal Information We Collect

1.1. Information you provide to us. Personal information you may provide includes:

  • Contact data: name, email address, billing and mailing addresses, phone number
  • Profile data: username, password, biographical details, interests, preferences, account information
  • Demographic data: date of birth, age, gender
  • Communications data: message contents from the Service or other contact
  • Transactional data: order information, order numbers, transaction history
  • Payment data: payment card information or bank account number (collected and stored by payment processors — not Asuna AI directly)
  • Marketing data: communication preferences and engagement details
  • User-provided content: text prompts, images, and other files you upload through the Service, plus associated metadata
  • Prompt and output data: prompts, descriptions, messages, and generated images produced through the Service
  • Feedback data: information about your Service experiences

IMPORTANT: YOU SHOULD NOT PROVIDE US WITH ANY CONFIDENTIAL, SENSITIVE, PROPRIETARY, OR BIOMETRIC INFORMATION THROUGH THE SERVICE.

1.2. Third-party sources. Asuna AI may combine your personal information with data from:

  • Public sources: government agencies, public records, social media platforms
  • Service providers: entities providing services on our behalf or operating the Service
  • Third-party services: social media or cloud platforms used to log in or link accounts (e.g., Google). Use of Google APIs adheres to the Google API Services User Data Policy, including Limited Use requirements.

1.3. Automatic data collection. Asuna AI and our service providers automatically collect:

  • Device data: operating system, browser type, screen resolution, IP address, unique identifiers, language settings
  • Online activity data: pages viewed, time on pages, navigation paths, access times, email interactions
  • Location data: when you authorize the Service to access device location
  • Communication interaction data: email open/click status via embedded tracking pixels

1.4. Data about others. If you invite contacts through the Service, we collect their information to deliver the invitation. Do not share someone's contact details without their permission.

1.5. Cookies and similar technologies. Automatic data collection is facilitated by cookies and similar technologies (see our Cookie Notice at asuna.ai/cookie-notice).

2. How We Use Your Personal Information

2.1. Service delivery and operations. We use personal information to:

  • Provide and operate the Service
  • Develop new features and services
  • Establish and maintain user accounts and profiles
  • Process and fulfill transactions
  • Facilitate image uploads, processing, and generation
  • Communicate about the Service, including updates, security alerts, and support messages

2.2. Personalization. We use information to:

  • Understand your needs and interests
  • Personalize your experience and related communications
  • Remember your selections and preferences

2.3. Service improvement and analytics. We use information to:

  • Analyze how the Service is used
  • Improve the Service, including using prompts and generated images to train AI models
  • Improve our business operations
  • Develop new products and services

2.4. Marketing. We and our service providers may send you marketing communications. You may opt out as described in Section 5.

2.5. Compliance and protection. We use information to:

  • Comply with applicable laws and legal process
  • Protect the rights, privacy, safety, and property of Asuna AI, users, or others
  • Enforce our Terms of Use
  • Prevent, investigate, and deter fraudulent, harmful, or unlawful activity

2.6. Aggregated and anonymized data. We may create aggregated, de-identified, or anonymized data and share it with third parties for lawful business purposes including Service improvement and business analytics.

3. Retention

3.1. General. We generally retain personal information for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements.

3.2. When information is no longer needed. We may delete, anonymize, or aggregate information when it is no longer needed for the applicable purpose.

4. How We Share Your Personal Information

We may share your personal information with:

  • Affiliates: Our corporate parent, subsidiaries, and affiliates
  • Service providers: Third parties providing services on our behalf (hosting, IT, customer support, email delivery, marketing, analytics)
  • Payment processors: Payment information is processed by third parties such as Stripe (stripe.com/privacy)
  • Advertising partners: Third-party companies for interest-based advertising
  • Parties you designate: Third parties where you've instructed or consented to sharing
  • Professional advisors: Lawyers, auditors, bankers, insurers as needed for professional services
  • Authorities and others: Law enforcement and government authorities where required by law or to protect rights and safety
  • Business transferees: Parties involved in actual or prospective mergers, acquisitions, or asset sales
  • Other users and the public: Your profile and any publicly shared content may be visible to other users

5. Your Choices

5.1. This section applies to all users; European users have additional rights in Section 11.

5.2. Access or update your information. Registered users may review and update account information by logging in.

5.3. Opt-out of communications. You may opt out of marketing emails by following unsubscribe instructions or contacting us at team@asuna.ai. We may continue to send service-related communications.

5.4. Cookies. See our Cookie Notice (asuna.ai/cookie-notice) for information on controlling cookies. Disabling cookies may affect Service functionality.

5.5. Do Not Track. Some browsers send "Do Not Track" signals. We currently do not respond to these signals.

5.6. Declining to provide information. You may choose not to provide certain information, but this may prevent us from providing some or all of the Service.

5.7. Delete your content or close your account. You may remove uploaded content at any time. Removed content may remain on active servers briefly and in backups for up to 90 days. You may request account closure at team@asuna.ai. Certain information may be retained for legal purposes.

6. Other Sites and Services

The Service may contain links to third-party websites and applications. Links to third-party content are not endorsements. Asuna AI does not control third-party services and is not responsible for their privacy practices. We encourage you to read their privacy policies.

7. Security

Asuna AI employs technical, organizational, and physical safeguards to protect your personal information. However, no internet transmission or storage system is 100% secure, and we cannot guarantee absolute security.

8. International Data Transfers

Asuna AI is headquartered in the United States. Personal information may be transferred to and processed in the U.S. or other countries, which may have privacy laws different from those in your jurisdiction.

9. Children

The Service is not directed to individuals under 18 years of age. If you believe we have inadvertently collected personal information from a minor, please contact us at team@asuna.ai and we will delete it.

10. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy. We will notify you of material changes by updating the date above and posting a notice on the Service. Your continued use after changes take effect constitutes your acceptance of the updated policy.

NOTICE TO EUROPEAN USERS

11. European User Privacy Rights

11.1. Scope. This section applies to individuals in the European Economic Area or United Kingdom ("Europe").

11.2. Personal data. References to "personal information" should be understood as "personal data" as defined in the GDPR (General Data Protection Regulation 2016/679 and applicable UK laws).

11.3. Controller. Asuna AI Inc. is the "controller" of your personal data. See Section 12 for contact details.

11.4. Our EU/EEA Representative. [YOUR EU REPRESENTATIVE — Contact datarep.com to establish representation before serving EU users]

11.5. Our UK Representative. [YOUR UK REPRESENTATIVE — required if processing UK personal data without a UK establishment]

11.6. Legal bases for processing. We process personal data under the following legal bases:

  • Contractual Necessity: Processing needed to deliver the Service or fulfill your requests
  • Legitimate Interests: Processing where our interests don't override your rights and freedoms
  • Compliance with Law: Processing to meet legal or regulatory obligations
  • Consent: Processing based on your specific consent

11.7. Processing purposes and legal bases:

| Purpose | Legal Basis | |---|---| | Service delivery and operations | Contractual Necessity; Legitimate Interests | | Personalization | Legitimate Interests; Consent (optional features/cookies) | | AI model improvement (prompts and outputs) | Legitimate Interests; Consent where required | | Marketing communications | Legitimate Interests; Consent where required | | Analytics and service improvement | Legitimate Interests; Consent (optional cookies) | | Legal compliance and protection | Compliance with Law; Legitimate Interests |

12. Retention (European Users)

12.1. We retain personal data as long as needed for the purposes described above, including for legal compliance, dispute resolution, and fraud prevention.

12.2. When data is no longer needed, we delete or anonymize it, or securely isolate it until deletion is possible.

13. No Sensitive Information (European Users)

Please do not submit sensitive personal data (racial or ethnic origin, political opinions, religious beliefs, health data, criminal background, biometric data, trade union membership). Submitting such data constitutes your consent to its processing per this policy.

14. No Automated Decision-Making

The Service does not engage in solely automated decision-making with legal or similarly significant effects on you.

15. Your Rights (European Users)

European data protection law gives you the right to:

  • Access: Request information about and access to your personal data
  • Correct: Request correction of inaccurate or incomplete data
  • Delete: Request deletion of your personal data where we have no lawful basis for continued processing
  • Portability: Receive a machine-readable copy of your data or have it transferred to another controller
  • Restrict: Request restriction of processing in certain circumstances
  • Object: Object to processing based on Legitimate Interests, including direct marketing
  • Withdraw Consent: Withdraw consent-based processing at any time (without affecting prior lawful processing)

To exercise any of these rights, contact us at team@asuna.ai. We may request identity verification and will respond within one month. We will explain any rejection. You also have the right to lodge a complaint with your local supervisory authority:

  • EEA: edpb.europa.eu/about-edpb/board/members_en
  • UK: ico.org.uk/make-a-complaint

16. International Transfers (European Users)

Asuna AI is U.S.-based. When we transfer personal data outside Europe, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission or reliance on adequacy decisions (e.g., the EU-U.S. Data Privacy Framework).

17. How to Contact Us

For questions about this Privacy Policy or to exercise your rights:

Asuna AI Inc. [YOUR ADDRESS] team@asuna.ai