Privacy Policy
| Field | Value |
|---|---|
| Version | 1.0 (draft) |
| Effective date | To be set |
| Last revised | 22 September 2026 |
| Approved by | Pending |
| Contracting entity | Substrate Artificial Inteligence, S.A. |
The full version history is available in the Legal document changelog.
This is a working draft adapted from the Serenity Star Privacy Policy. It has not been reviewed by Legal and is not yet in force.
This Privacy Policy will explain how Substrate Artificial Inteligence, S.A. collects and processes personal data when you use Serenity Edge and this website, acting as Data Controller. It does not apply where Substrate AI processes personal data on behalf of a Commercial Customer as Data Processor; the Data Processing Agreement governs that processing. What follows is the outline of the final document, following the structure of the Serenity Star Privacy Policy.
Overview
Scope
1. Definitions
2. Who is the Data Controller?
Substrate Artificial Inteligence, S.A., NIF A98306228, Avenida Real Fábrica de Sedas 28, 45600 Talavera de la Reina (Toledo), Spain. Contact: [email protected]. Data Protection Officer: to be confirmed by Legal.
3. What kind of personal data do we collect?
- Identity and contact data of the people who contact us or sign a contract.
- Account and billing data: for Serenity Star account traffic, collected and processed by Serenity Star as described in its own Privacy Policy.
- Request metadata: timestamps, token counts, model, latency and status of each API request. No prompt or completion content.
- Website data: server logs and, subject to consent, the cookies described in the Cookie Policy.
4. Why do we use your personal data?
Providing and billing the service, security and abuse prevention, capacity planning, legal obligations, communication with customers. Service improvement never includes training models on user data.
5. How long do we store your personal data?
Request metadata: 90 days. Prompts and completions: not stored. Contract and invoicing data: statutory periods under Spanish law.
6. Who do we share your personal data with?
Serenity Star (authentication and billing for account traffic), Microsoft Azure (request handling in Spain Central), and the other providers listed at Sub-processors.
7. Do we transfer your personal data outside the EU?
No. Inference runs on Substrate AI's own GPUs in Valencia, Spain; request handling runs in Microsoft Azure Spain Central; authentication and billing for Serenity Star account traffic run in Azure France Central.
8. Your rights
Access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with the Spanish Data Protection Agency (AEPD).