Privacy Policy

Effective Date: 12 October 2026

1. Introduction

This Privacy Policy explains how XERLYX OÜ processes data when users interact with MetaLearn X, HumanScan X, or any mechanistic agents operated by XERLYX.By using XERLYX systems, you consent to this Policy.XERLYX systems are non‑clinical, non‑medical, non‑therapeutic, and strictly mechanistic.

2. Data Collected

2.1 User‑Provided Data

XERLYX may collect:

  • text inputs

  • organizational descriptions

  • identity‑related descriptions

  • email addresses (for delivery)

  • payment information (via Stripe)

2.2 System‑Generated Data

XERLYX may generate and store:

  • analysis results

  • mechanistic reports

  • structural mappings

  • agent interaction logs

  • usage metadata

2.3 Automatically Collected Data

XERLYX may collect:

  • IP address

  • device type

  • browser type

  • access timestamps

  • system performance metrics

3. Purpose of Data Processing

Data is processed to:

  • operate mechanistic agents

  • generate analysis results

  • deliver reports

  • maintain system integrity

  • improve reliability

  • prevent misuse

  • comply with legal obligations

Data is not used for:

  • psychological evaluation

  • medical diagnosis

  • therapeutic decision‑making

  • advertising

  • behavioral profiling outside mechanism analysis

4. Legal Basis for Processing

Processing is based on:

  • consent

  • contractual necessity

  • legitimate interest (system security)

  • legal compliance

5. International Transfers

Data may be transferred outside the EU.
All transfers follow GDPR safeguards, including Standard Contractual Clauses (SCCs) and compliance frameworks.

6. Cookies

Certain third-party providers, including payment and membership systems, may use essential cookies required for operation.

7. Data Storage & Retention

Data may be stored:

  • temporarily (for service operation and analysis)

  • persistently (for audit, quality, and fraud prevention)

Retention periods vary based on:

  • legal requirements

  • operational needs

  • licensing agreements

Users may request deletion where legally applicable.

8. Data Sharing

Data may be shared only with:

  • payment processors

  • membership and authentication providers

  • email delivery providers

  • infrastructure and hosting providers

  • legal authorities (if required by law)

8. 1 THIRD-PARTY SERVICE PROVIDERS

XERLYX may use trusted third-party service providers
to operate, maintain, secure, and deliver its services.These providers may process data solely as necessary
for payment processing, membership management,
authentication, artificial intelligence processing,
infrastructure, communications, security,
and service delivery.All third-party providers are expected to maintain
appropriate security, privacy, and compliance standards
applicable to their services.

9. Security Measures

XERLYX implements:

  • encrypted transport

  • access controls

  • audit logs

  • system integrity monitoring

  • rate‑limiting

  • anomaly detection

Users accept inherent digital service risks.

10. User Rights (GDPR)

Where applicable, users may:

  • request data access

  • request correction

  • request deletion

  • request processing limitation

  • request portability

  • withdraw consent

Requests may be denied if they compromise system integrity or legal obligations.

11. Children & Youth Data

Youth Mechanism analysis require parental or legal guardian consent.
XERLYX does not knowingly collect data from minors without authorization.

11.1 Minor Data Handling

XERLYX does not knowingly collect or process personal data from minors without parental or legal guardian authorization.
Any data submitted by a minor without such authorization is the responsibility of the submitting party.
Parents or guardians may request deletion of minor data where legally applicable.
XERLYX is not responsible for any content accessed by minors without supervision, nor for any interpretative or moral disagreements arising from such access.

12. Changes to Policy

XERLYX may update this Policy at any time.
Continued use constitutes acceptance.

13. Contact

XERLYX OÜ
Tallinn, Estonia
[email protected]

© XERLYX OÜ. All rights reserved.