Privacy Policy

Effective Date: April 15, 2025

INTRODUCTION

At Black Crow AI, your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you access or use our website, platform, or products (the "Services"). By using the Services, you acknowledge and accept the practices described in this Policy.

This Privacy Policy applies to all individuals whose personal data we process, including:

• Website visitors
  
  
• Prospective and current merchant customers
  
  
• End users of our self-service tools (like Storefronts), where we act as a data controller
  
  
• Customer end users, where we act as a data processor in accordance with our contractual obligations
  
  

Please note: This Privacy Policy primarily governs how we process personal data in connection with our direct relationships — for example, when we interact with merchant customers, prospects, or visitors to our Services.

When we process personal data on behalf of our business customers (such as data about their end users or site visitors), we act as a data processor. In those cases, our use of the data is governed by a contract with the customer — not this Privacy Policy — and the customer's own privacy policy applies. If you are an end user of one of our customers and wish to exercise your privacy rights, please contact the relevant business directly.

How We Operate:

• We are a controller of personal data from our merchant customers — for example, when they create an account, provide billing information, or use Storefronts.
  
  
• We are a processor of personal data from end users of our customers (e.g., shoppers visiting a storefront built with our tools). That data is governed by our customer's privacy policy.
  
  

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SUMMARY: WHAT THIS POLICY MEANS FOR YOU

• We collect personal data to provide and improve our Services.
  
  
• For our self-service tools, we act as a data controller for merchant customer data.
  
  
• For data about your customers (e.g., site visitors), we act only as a processor.
  
  
• We use subprocessors, including AI providers, to help us operate and improve the Services.
  
  
• You have rights and choices under applicable privacy laws, including access, deletion, and opt-out.
  
  

TABLE OF CONTENTS

1. What This Privacy Policy Covers
   
   
2. Personal Data We Collect
   
   
3. Sources of Personal Data
   
   
4. Use of Personal Data
   
   
5. How We Share Personal Data
   
   
6. Tracking Tools and Preference Signals
   
   
7. Data Security and Retention
   
   
8. Personal Data of Children
   
   
9. Your Privacy Rights
   
   
10. Data Subject Rights (EU/UK)
    
    
11. Data Transfers
    
    
12. Changes to This Privacy Policy
    
    
13. Contact Information
    
    

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1. WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy describes how Black Crow AI collects and uses personal data in connection with our Services. "Personal Data" means any information that identifies or relates to an individual, including identifiers like names, email addresses, or online identifiers.

Black Crow AI acts as:

• A data controller for personal data we collect directly from our merchant customers (e.g., name, email, billing information, account usage).
  
  
• A data processor for personal data we process on behalf of our customers related to their end users (e.g., shoppers visiting storefronts built using our tools).
  
  

For processor relationships, our use of personal data is governed by our SaaS Terms of Service or another agreement with the customer. If you are an end user of one of our customers, please contact them directly to manage your data.

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Role Summary Table

Data Type

Black Crow AI Role

Applies to

Merchant signup data

Controller

Email, name, billing info

Storefront visitor data

Processor

Shopper behavior, form entries

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2. PERSONAL DATA WE COLLECT

We have collected the following categories of personal data in the last 12 months:

Category

Examples

Shared With

Profile or Contact Data

Name, work email

Service Providers, Authorized Parties

Online Identifiers

Device ID, cookie identifiers

Analytics & Advertising Partners, Service Providers

User-Submitted Content

Inputs to landing page tools (e.g. Storefronts)

AI Subprocessors, Service Providers

Communications

Messages or emails you send us

Customer Support Providers

3. SOURCES OF PERSONAL DATA

We collect data:

• Directly from you when you use or submit content to our Services
  
  
• Automatically from your browser or device
  
  
• Through cookies and similar technologies
  
  
• From third-party services like analytics or advertising tools
  
  

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4. USE OF PERSONAL DATA

We use your personal data to:

• Provide and manage the Services
  
  
• Customize and personalize experiences
  
  
• Process payments and transactions
  
  
• Respond to inquiries or issues
  
  
• Improve our tools and models (including AI services)
  
  
• Conduct marketing (with consent, if required)
  
  
• Meet legal obligations and enforce our terms
  
  

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5. HOW WE SHARE PERSONAL DATA

We may share personal data with the following categories of recipients:

Type

Description

Service Providers

Cloud hosting, infrastructure, fraud prevention

Analytics Providers

Help us understand usage and improve Services

AI Subprocessors

Power Storefronts' AI features (e.g., OpenAI LLMs); used solely to deliver functionality

Advertising Partners

For promoting our Services; never for selling your data

Legal Authorities

If required by law or to enforce rights

Business Transfers

In M&A, restructuring, or bankruptcy events

Note: Subprocessors are contractually bound to process your data only for our purposes, not their own.

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6. TRACKING TOOLS AND PREFERENCE SIGNALS

We use cookies and similar technologies (e.g., pixels, beacons) to:

• Recognize repeat users
  
  
• Analyze traffic and usage
  
  
• Customize content and ads
  
  

We do not sell personal data. While our Services do not support "Do Not Track" (DNT) browser settings, we do recognize legally required opt-out signals, such as the Global Privacy Control (GPC), where applicable.

To manage cookies or GPC, adjust your browser settings or visit www.allaboutcookies.org to learn more.

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7. DATA SECURITY AND RETENTION

We implement technical and organizational measures to protect your data, including:

• Encryption in transit and at rest
  
  
• Role-based access controls
  
  
• Periodic audits and activity logs
  
  

We retain personal data only as long as needed for our business or legal purposes. We periodically review our retention schedules to avoid keeping data longer than necessary.

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8. PERSONAL DATA OF CHILDREN

We do not knowingly collect data from children under 16. If you believe a child has provided us data, contact us at privacy@blackcrow.ai.

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9. YOUR PRIVACY RIGHTS (US STATES)

If you reside in certain U.S. states (e.g., California, Nevada), you may:

• Request disclosure of what personal data we collect
  
  
• Request deletion of your data
  
  
• Opt out of certain uses of your data (including GPC signal recognition)
  
  

To exercise your rights, email: privacy@blackcrow.ai

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10. DATA SUBJECT RIGHTS (EU/UK)

If you are in the EU or UK, you may have the following rights under GDPR:

• Access your personal data
  
  
• Request correction or deletion
  
  
• Withdraw consent at any time
  
  
• Object to processing or restrict it
  
  
• Request data portability
  
  
• Lodge a complaint with your supervisory authority
  
  

We act as a data controller for personal data we collect directly (self-serve merchants) and as a data processor when we handle end-user data on behalf of business customers. If you are an end user of a merchant using our services, please direct any privacy requests to that merchant.

11. DATA TRANSFERS

Your data may be transferred to or processed in the United States. Where required by law, we use safeguards like:

• Standard Contractual Clauses (SCCs)
  
  
• Data Processing Agreements (DPAs)
  
  

12. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time. If we make material changes, we will notify you via email or notice on our website.

13. CONTACT INFORMATION

General inquiries / Data Subject Requests:
Email: privacy@blackcrow.ai
Address: 447 Broadway, 2nd FL #382, New York, NY, 10013

EU Representative:
DP-Dock GmbH
Attn: Black Crow AI, Ballindamm 39, 20095 Hamburg, Germany
Email: blackcrowai@gdpr-rep.com

UK Representative:
DP Data Protection Services UK Ltd.
Attn: Black Crow AI, 16 Great Queen Street, London, WC2B 5AH, United Kingdom
Email: blackcrowai@gdpr-rep.com

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