Effective Date: September 22, 2025

This Privacy Policy outlines how Oceania AI ("we," "our," or "us") collects, uses, stores, and protects the personal and proprietary information of our customers and collaborators. We are committed to transparency and to meeting the highest standards of data protection, including those set forth by the International Organization for Standardization (ISO) and the General Data Protection Regulation (GDPR).

1. Information We Collect

We collect information for specific, legitimate business purposes. The types of information we may collect include:

• Contact Information: Name, email address, phone number, and company name, which you provide when you communicate with us or engage our services.

• Customer Proprietary Information (CPI): Confidential and proprietary data shared by you for the purpose of a specific project or engagement.

• Billing and Financial Information: Data necessary for processing payments and maintaining taxation records.

2. How We Use Your Information

We use the information we collect solely for the following purposes:

• To provide and improve our services to you.

• To communicate with you regarding your projects and our services.

• To process payments and manage our business operations.

• To comply with our legal and regulatory obligations, including tax record-keeping.

3. Data Storage and Security

• Storage Location: All information is stored securely within our Google Workspace tenancy. Google Workspace's security measures and certifications provide a robust and compliant platform for data storage.

• Data Minimization: We only collect and retain the data that is necessary for the specified purposes.

• Security Measures: We implement a range of technical and organizational security measures to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include access controls, encryption, and regular security audits.

4. Data Retention

• Confidential Information: At the end of an engagement, any confidential information shared by our customers is promptly and securely deleted. We do not retain this data unless explicitly instructed and agreed upon in writing.

• Taxation Records: We are legally required to retain certain financial and transaction data for a period of seven (7) years for taxation purposes. After this period, such data is securely disposed of.

• Contact Information: We retain contact information for the duration of our business relationship and for a reasonable period thereafter for administrative purposes, unless you request its earlier deletion.

5. AI System Usage (Gemini)

Oceania AI uses Gemini, a closed-loop AI system, to assist in our operations.

• No Data Sharing: Gemini does not share any customer proprietary information (CPI) or personal identifying information (PII) with any third parties.

• No Training Data: The data you share with us is not used to train or improve the Gemini AI model. The system processes your data in a secure, isolated environment and does not retain it for future use.

6. Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal or proprietary information to outside parties. Your information is not shared with any third parties unless:

• It is necessary to provide a service you have requested (e.g., sharing billing information with a payment processor).

• We are legally required to do so by a court order or other legal process.

• You have given your explicit consent.

7. Your Rights Under GDPR

If you are a resident of the European Economic Area (EEA), you have the following rights concerning your personal data:

• Right to Access: You have the right to request a copy of the personal data we hold about you.

• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.

• Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal data under certain circumstances.

• Right to Restrict Processing: You have the right to request a temporary halt to the processing of your personal data.

• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes.

• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the details provided below. We will respond to your request within a reasonable timeframe and in accordance with applicable laws.

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on our website and updating the "Effective Date" at the top of the policy.

9. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer at:

privacy@oceania.ai