隐私政策

1. Introduction

Wyrmlabs Ltd. ("Wyrmlabs," "we," "us," "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including the Fathom model, our website, API, and associated platforms (collectively, the "Services").

Wyrmlabs is an AI research laboratory headquartered in Zhongguancun Science Park, Haidian District, Beijing, China. We comply with applicable data protection laws, including the Personal Information Protection Law of the People's Republic of China (PIPL) and the European Union's General Data Protection Regulation (GDPR) where applicable.

2. Information We Collect

We may collect the following types of information:

• Account Information: When you register, we collect your email address, name, and authentication credentials.
• Usage Data: Information about how you interact with the Services, including prompts submitted, responses generated, timestamps, and feature usage patterns.
• Technical Data: IP address, browser type, device identifiers, operating system, and log data.
• Communication Data: Information you provide when contacting our support team or participating in research surveys.
• Payment Information: For paid services, we collect billing information through our third-party payment processors. We do not store full payment card details.

3. How We Use Your Information

We use the collected information for the following purposes:

• Providing, maintaining, and improving the Services;
• Processing transactions and managing accounts;
• Responding to your inquiries and providing customer support;
• Analyzing usage patterns to optimize model performance and user experience;
• Detecting and preventing abuse, fraud, or unauthorized access;
• Complying with legal obligations and enforcing our Terms of Service;
• Sending service-related communications and, with your consent, marketing materials.

Important: We do not use your prompts, inputs, or conversational data to train or fine-tune our models unless you have explicitly opted in. If you opt in, your data may be used for training purposes after de-identification and removal of personally identifiable information.

4. Data Retention

We retain your information for as long as your account is active or as needed to provide you the Services. Usage logs are retained for a period of 12 months, after which they are anonymized or deleted. Account information is retained until account deletion, after which residual copies may remain in our backup systems for up to 90 days. You may request deletion of your account and associated data at any time by contacting our privacy team.

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

• With third-party service providers who perform services on our behalf (cloud infrastructure, analytics, payment processing) under contractual obligations of confidentiality;
• To comply with legal obligations, court orders, or governmental requests, subject to applicable law;
• In connection with a merger, acquisition, or sale of assets, with notice to you;
• With your explicit consent or at your direction.

6. International Data Transfers

As a global company operating from Beijing, your information may be transferred to, stored, and processed in servers located in China and other jurisdictions. We implement appropriate safeguards, including Standard Contractual Clauses and data processing agreements, to ensure your information receives adequate protection in accordance with applicable data protection laws.

7. Data Subject Rights

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

• Right to access the personal data we hold about you;
• Right to rectify inaccurate or incomplete data;
• Right to erasure ("right to be forgotten") subject to legal retention requirements;
• Right to restrict or object to processing;
• Right to data portability;
• Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, contact us at legal@wyrmlabs.be. We will respond to your request within 30 days.

8. Security

We implement appropriate technical and organizational measures to protect your information, including encryption at rest and in transit, access controls, regular security audits, and employee training on data protection practices. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

9. Cookies

Our website uses essential cookies for authentication and security purposes. We also use analytics cookies to understand usage patterns. You can control cookie preferences through your browser settings. Third-party services integrated with our Services may place their own cookies subject to their respective privacy policies.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or through a prominent notice on our website. Your continued use of the Services after the effective date of the updated policy constitutes acceptance of the changes.

11. Contact

For questions or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer:

Email: legal@wyrmlabs.be
Address: Wyrmlabs Ltd., Data Protection Officer, Zhongguancun Science Park, Haidian District, Beijing, 100080, China