Legal document changelog
| Field | Value |
|---|---|
| Version | 1.0 (draft) |
| Effective date | To be set |
| Last revised | 22 September 2026 |
| Approved by | Pending legal review |
| Contracting entity | Substrate Artificial Inteligence, S.A. |
This is a working draft adapted from the Serenity Star Legal document changelog. It has not been reviewed by Legal and is not yet in force.
This page records the version history of the Legal notice, the Terms of Service, the Privacy Policy, the Data Processing Agreement, the Sub-processors list, the Acceptable Use Policy and the Cookie Policy, and states from which date each version applies.
Version 1.0 (draft)
Drafted 22 September 2026. Effective date to be set. First full drafts of the eight legal documents of Serenity Edge, pending legal review:
- Legal notice
- Terms of Service
- Privacy Policy
- Data Processing Agreement
- Sub-processors
- Acceptable Use Policy
- Cookie Policy
- This changelog
None of these documents is in force. Each carries a document control block stating "Version 1.0 (draft)", "Effective date: to be set" and "Approved by: pending legal review", and a draft notice that will be removed when Legal approves them. The effective date will be recorded here when it is set.
Origin of the documents
The Terms of Service, the Privacy Policy, the Data Processing Agreement and the Sub-processors list are adapted from version 2.0 of the corresponding Serenity Star documents, published by Subgen AI Spain, S.L. on 31 August 2026 with effect from 1 October 2026. Their structure, definitions, tone and level of detail have been kept; every provision that only made sense for the Serenity Star platform (agents, workspaces, subscription plans, the credits interface, Google user data, moderation filters and the chat widget) has been removed, and every provision has been rewritten for an inference API sold by a different entity. The Legal notice, the Acceptable Use Policy and the Cookie Policy are new: the Serenity Star site does not publish equivalents, and the acceptable use rules that sit inside section 8 of the Serenity Star Terms of Use have been moved into a separate policy that the Terms of Service incorporate by reference.
Contracting entity
The contracting entity, data controller and data processor under these documents is Substrate Artificial Inteligence, S.A., a company incorporated under the laws of Spain and listed on BME Growth, with Spanish tax identification number (NIF) A98306228, registered with the Commercial Registry of Toledo under Section 8, Sheet TO-48960, with its registered office at Avenida Real Fábrica de Sedas 28, 45600 Talavera de la Reina (Toledo), Spain. The volume and folio of the registry entry are to be completed by Legal. The single contact address for notices, privacy requests and legal matters is [email protected]. No Data Protection Officer has been designated.
Subgen AI Spain, S.L., the contracting entity of the Serenity Star documents, appears in the Serenity Edge documents as a group company of Substrate AI: it operates the facility in Valencia where inference runs and operates the Serenity Star accounts through which customers may obtain API keys and credits. The intra-group data processing agreement between the two companies is in preparation.
Governing law and jurisdiction
Spanish law governs every document. The courts of Madrid, Spain, have jurisdiction, replacing the courts of Valencia named in the Serenity Star documents; this choice is pending legal validation. The consumer carve-out of the Serenity Star documents has been kept: a consumer does not lose the protection of the mandatory provisions of the law of their country of residence, may bring proceedings either before the courts of their place of residence or before the courts of Madrid, and may only be sued before the courts of their place of residence.
Access routes
The Terms of Service describe the three routes through which Serenity Edge can be used and what each one entails: through OpenRouter, where the customer's contract is with OpenRouter and Substrate AI is a provider on that marketplace; with a Serenity Star account, where account creation, API keys, credits and billing are operated by Subgen AI Spain, S.L. under the Serenity Star terms as a group company acting for Substrate AI; and under an enterprise contract negotiated individually, which is the only route with a service level agreement. The Data Processing Agreement and the Sub-processors list treat OpenRouter as an independent marketplace rather than a sub-processor, and Serenity Star as an access route provider engaged only when the customer chooses that route.
Data policy
The documents record the zero-retention design of the service as a binding commitment: prompts and completions are processed in memory and are not stored or logged anywhere in the pipeline; no customer content is used to train any model; only request metadata (timestamps, token counts, model, latency, status codes and API key identifier) is kept, for 90 days, for billing, security and operations. Inference runs on Substrate AI's own GPU infrastructure in Valencia, Spain; request handling runs in Microsoft Azure Spain Central; authentication and billing for Serenity Star account traffic run in Microsoft Azure France Central. No personal data is transferred outside the European Union. The Data Processing Agreement adapts the Article 28 GDPR clauses to that design: data subject requests, breach notification, return and deletion at the end of the services and audits are all expressed for a processor that retains nothing.
Fees and service levels
Fees are published per million tokens, in United States dollars, and are metered on the usage object of each response. Price increases are announced with at least thirty days of notice. Prepaid credits are non-refundable except where the law requires otherwise, including the consumer right of withdrawal. Outside an enterprise contract the service is provided on commercially reasonable efforts, without a service level agreement, and rate limits are enforced with HTTP 429 responses. Models may be added, updated or retired; retirement carries at least thirty days of notice except for security or legal reasons.
Sub-processors
The Sub-processors list names Cloudflare, Inc. (edge network), Microsoft Ireland Operations Limited (Microsoft Azure Spain Central for request handling and, for the Serenity Star route, France Central) and Subgen AI Spain, S.L. (operation of the Valencia facility and of Serenity Star accounts). A row for the status page provider is marked "to be confirmed".
Document control
Every document carries a version number, an effective date, a last-revised date, the approver and the contracting entity. This changelog is the version history they refer to.