Privacy Policy – Velyx.ai

1. Introduction

Velyx.ai is an AI-powered chatbot with live chat functionality ("ChatBot") that enables car dealerships ("Dealers") to answer customer enquiries around the clock ("Services"). Our technology utilises state-of-the-art independent open-source Large Language Models (LLMs) for processing enquiries.

This privacy policy helps customers using our services (collectively referred to as "You") and the dealers understand what data we collect and use on behalf of a dealership and what choices you have regarding that data. By operating the ChatBot for the dealership, Velyx acts as a data processor for the dealership, and all communication between you and the ChatBot is processed by Velyx on behalf of the dealership.

2. Collection of Information About User Behaviour and Personal Data

When you visit a website ("Website") that has integrated the ChatBot, Velyx may collect, store and use information. When you enter data such as your name, appointment details, vehicle preferences or price comparison links, this information is stored and linked to the "behavioural data" we collect.

"Personal data" is personally identifiable information such as your first name, last name, phone number or email address. We store transcripts of chat conversations and link them to your personal data. We use this data to:

• Book appointments based on your confirmation.
• Store vehicle preferences to notify you by email when a specific vehicle becomes available.

3. Cookies and Other Tracking Technologies

To provide a personalised service, we may use cookies to track behaviour. Collected data includes:

• Your domain names and IP address;
• Web browser, device and operating system types;
• Pages visited or files requested.

You can block cookies via your browser settings or the website's consent management tool.

4. Linking Behavioural Data with Personal Data

If you voluntarily share your name and contact details with Velyx during a live chat, we may link your previous behavioural data (pages visited, vehicles viewed) with your personal identity to enable a more relevant service for the dealership.

5. Legal Basis for Processing

Velyx processes data as a processor on behalf of the controller (the dealership). Processing is lawful under the GDPR when:

• Consent: You give explicit permission via the chat or cookie banner.
• Performance of a contract: To provide a service you have requested (e.g., booking a test drive).
• Legitimate interest: To improve dealership efficiency and 24/7 customer availability.

6. Disclosure of Personal Data

We do not sell your personal data. We only share data with:

• The Dealership: The primary entity for which we process data.
• Inference Providers: We use specialised providers such as Nvidia (NIM) or OpenRouter to run open-source models. We ensure these providers do not use your data to train their global base models.
• Hosting Services: We use secure European infrastructure providers (see Section 7).

7. Storage and Data Sovereignty

HOSTING & INFRASTRUCTURE

Velyx AI is committed to European data sovereignty. All AI model processing and data storage are hosted on European servers (EU).

Current Status: We use Hetzner to ensure all data remains within the EEA. This prevents the transfer of sensitive data to non-EU jurisdictions and ensures compliance with the highest German and European data protection standards.

8. Retention Periods

We retain behavioural and personal data for 6 months, or as long as necessary to comply with legal or reporting requirements. After this period, data is permanently deleted or anonymised.

9. Your Privacy Rights

Under the GDPR, you have the right to access, rectify or delete your data, as well as the right to object to processing. To exercise these rights, please contact: [email protected].

10. Data Breach

Should a data breach occur that is likely to significantly affect your rights, we will promptly notify the controller (the dealership), who is responsible for further communication with you.

11. Your Consent

BY USING OUR CHATBOT, YOU AGREE TO:

• (A) The collection, use and disclosure of your data as described in this policy.
• (B) Having read the privacy policy of the respective dealership.

(Note: Since Velyx uses open-source models, your data is NOT subject to OpenAI's privacy terms unless you explicitly opt for forwarding there.)

12. Third-Party Websites

The ChatBot may contain links to social media or partner websites of the dealership. We are not responsible for the privacy practices of these third-party websites.

13. Amendments & Contact

We review this policy regularly. For questions, contact: [email protected].