AI Data & Training Policy
Effective date: June 17, 2026
This policy explains how AI features across the APERTURESyndicate platform process your data, who performs the underlying model computations, and — most importantly — our firm commitment that we never use your personal content to train or fine-tune AI models unless you explicitly opt in.
It applies to ASAI (AI chat, roleplay, ASAI Code, and AI image generation, including persistent AI "memory" features) and to AI-assisted functionality offered through ASMusic, ASVentor, ASChat, ASDev, ASAIStudio, and LQ (Lysicon Quanture).
AI features are available only to registered users aged 16 or older.
This policy is part of, and should be read together with, our Privacy Policy, our Data Retention Policy, and our AI Output & Limitations notice. Company and registry details are published at Company Registration.
This policy is a working text pending review by qualified EU/Estonian legal counsel; it may be refined for legal precision without weakening the user commitments stated here.
1. Controller
The data controller for AI features is APERTURESyndicate OÜ (registry code 17384111, VAT EE102972654), Priisle tee 8, Lasnamäe linnaosa, Tallinn 13914, Estonia. Our single point of contact for all privacy, AI, and data matters is [email protected].
2. What Our AI Features Process
When you use an AI feature, we process the data you provide and the data needed to generate a response:
- Prompts — the text, instructions, and questions you send to an AI feature.
- Conversation history — prior turns in a chat, roleplay, or coding session, used so the AI can maintain context within that session and across sessions you choose to keep.
- Roleplay content — characters, scenarios, and dialogue you create or interact with.
- Uploaded files — documents, images, code, and other files you attach to an AI feature for it to act on.
- AI "memory" — facts, preferences, and context that AI features derive from your use over time so they can respond more helpfully. You can view, edit, and delete this memory in your account settings, and disabling memory stops new memory from being created.
We process this data to deliver the feature you requested, to maintain your account, to keep the service secure and reliable, and to comply with our legal obligations. The legal bases for this processing are set out in our Privacy Policy.
3. Who Runs the Models (Sub-Processors)
We do not operate the large AI models ourselves. Inference — the computation that turns your prompt into a response — is performed by specialised third-party model providers acting as our GDPR sub-processors under contractual data-protection terms.
To deliver AI features, the content you submit (and the context required to answer it) may be transmitted to specialised providers in the following categories:
| Category of recipient | What is sent, and when |
|---|---|
| AI inference providers | Prompts, conversation context and attached images — for every request to ASAI Mini and ASAI Arc, and for text embeddings and AI image generation and editing. |
| Speech-to-text providers | Audio only, and only when you attach or link audio or video, or dictate by voice. |
| Web search and retrieval providers | Your search query, or the URL you supplied — only where a feature looks something up live to ground its answer. |
| Document parsing providers | The uploaded file — only where a PDF or document has to be converted into text before an AI feature can read it. |
Every provider in these categories is contractually bound as our GDPR sub-processor: they act only on our instructions, process the data only to perform the operation requested, and may not use your content for their own purposes or to train their own models. Transfers outside the EEA are covered by Standard Contractual Clauses or an adequacy decision, as set out in the sub-processor register.
What we publish, and what we do not. Our products are ASAI Mini and ASAI Arc. Which models sit behind those names, and which specific vendors provide the infrastructure underneath, is confidential to our business — we describe recipients by category, which is what Article 13(1)(e) of the GDPR requires, rather than exposing our stack. We change models and infrastructure providers as the technology moves, without that being a change to this policy; what does not change is the category of processing described above and the protections attached to it.
If you are a business customer and your own compliance obligations require the named list, ask us at [email protected] and we will provide it under confidentiality.
Outside AI generation, the platform is supported by payment, hosting, network security and error-tracking providers — those are named in the sub-processor register, because they are not part of our AI stack.
These providers act on our instructions, process the data only to perform the requested operation, and are bound not to use your content for their own purposes. Our current sub-processor list and any updates are described in our Privacy Policy.
AI output is generated, not retrieved from other people. Responses are produced by a model computing over your input — they are not pulled from, and do not expose, another user's chats, files, or memory.
4. Training: Opt-In Only
We do not use your personal content to train or fine-tune AI models unless you have explicitly opted in.
This is an unconditional commitment. By default — and unless you actively choose otherwise — none of the following is ever used to train, fine-tune, or otherwise develop AI models, by us or by our sub-processors:
- your prompts;
- your conversation, chat, or coding history;
- your roleplay content;
- your uploaded files;
- your AI memory.
4.1 How to opt in or out
Training participation is controlled by you in your account privacy settings, under the AI data controls:
- To opt in: enable the "Help improve AI models with my content" setting. Opting in is entirely voluntary and is never a condition of using any AI feature.
- To opt out: turn the same setting off. It is off by default, so no action is required to stay out.
You may change your choice at any time. Opting out stops any further use of your content for training going forward. Content already incorporated into a trained model cannot be extracted from that model, but no new content will be used once you opt out, and your withdrawal does not affect the lawfulness of processing carried out while opt-in was active.
If you opt in, we will use the content only to improve model quality and only under appropriate safeguards; opting in does not change any of the other protections in this policy, including Section 5.
5. Inferences We Will Not Make About You
We design our AI features to assist you, not to profile you. We do not use AI features to:
- provide medical, psychiatric, or psychological diagnoses about you; or
- infer your sexual orientation, gender identity, political opinions, religious or philosophical beliefs, financial status, health conditions, immigration status, or criminal history.
If you choose to state any of this information yourself, the AI may use it within your session to respond to your request, subject to the rest of this policy and your settings. We do not attempt to derive these special categories of data from your behaviour, and we do not build advertising or risk profiles from your AI activity.
6. Operational Signals Used to Improve the Service
Separately from your content, we may generate and analyse anonymised, aggregated operational signals about how the system itself is performing — for example, overall request volumes, error and latency patterns, feature usage trends, and aggregate quality measures.
These signals describe the behaviour of the service, not your identity or the substance of your conversations. They are aggregated across many users and stripped of information that could identify you or reveal what you wrote, and we use them only to keep the platform fast, stable, and reliable and to improve features. This is distinct from the training described in Section 4 and does not rely on, or require, your opt-in.
7. AI Transparency (EU AI Act)
When you use an AI feature, you are interacting with an artificial-intelligence system, not a human. We label AI features clearly so this is never ambiguous.
AI systems can produce output that is inaccurate, incomplete, outdated, or misleading, and AI-generated images or text may not reflect reality. Do not rely on AI output for medical, legal, financial, or other professional decisions without independent verification by a qualified professional. For the full explanation of what our AI can and cannot do, see AI Output & Limitations.
8. Your GDPR Rights
As a data subject in the European Union, you have the right to access, rectify, erase, restrict, and port your personal data, to object to certain processing, and to withdraw consent (including your training opt-in) at any time without affecting prior lawful processing.
You can exercise most controls directly in your account settings (including viewing and deleting AI memory and changing your training choice), or by contacting [email protected]. Full details on how to exercise each right, and your right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), are set out in our Privacy Policy.
9. Retention
AI-related data — including prompts, conversation history, roleplay content, uploaded files, and AI memory — is retained only as long as needed to provide the feature and meet our legal obligations, and is deleted or anonymised after that. Deleting a conversation, clearing your AI memory, or deleting your account removes the associated content according to the schedule in our Data Retention Policy.
10. Changes to This Policy
We may update this policy as our AI features, sub-processors, or legal obligations change. Material changes will be communicated through the platform, and the "Last updated" date above will always reflect the current version. We will never retroactively weaken the opt-in-only training commitment in Section 4 for content already processed under this policy.
Contact
For any question about this policy or your data, contact [email protected].
Version history
- v1.2 — 2026-08-01 — Section 3 now describes recipients by category — AI inference, speech-to-text, web retrieval, document parsing — instead of naming individual vendors. Our products are ASAI Mini and ASAI Arc; the models and infrastructure behind them are confidential to our business. Category-level disclosure is what Article 13(1)(e) of the GDPR requires, and business customers who need the named list for their own compliance can request it under confidentiality.
- v1.1 — 2026-08-01 — Section 3 corrected to match what the service actually does: which stage of processing goes to which category of provider, and that speech-to-text is transcription only. Added an explicit statement that we do not publish which models sit behind the ASAI Mini and ASAI Arc product names.
- v1.0 — 2026-06-22 — Initial publication.
This document is provided in English, which is the controlling language; any translation is for convenience only.