Effective date: The date displayed when this Privacy Policy is published or last updated on Univerax.
1.1. This Privacy Policy explains how Zenlyai OÜ, trading as Univerax (“Univerax,” “we,” “us,” or “our”), collects, uses, discloses, stores, protects, and otherwise processes personal data through Univerax, its websites, applications, interfaces, communications, and related services (collectively, the “Platform”).
1.2. This Privacy Policy applies to Customers, Creators, visitors, account holders, recipients of communications, and other individuals who interact with the Platform.
1.3. This Privacy Policy covers personal data processed in connection with:
a. account registration and authentication;
b. profiles, professional networks, and social features;
c. physical products, Digital Content, Services, and Bookings;
d. payments, commissions, refunds, and payouts;
e. Creator and Customer communications;
f. reviews, ratings, reports, and support requests;
g. analytics, search, ranking, and recommendations;
h. artificial intelligence features;
i. Digital Twins; and
j. security, fraud prevention, moderation, and legal compliance.
1.4. This Privacy Policy does not govern an independent Creator’s processing of personal data outside Univerax’s control. Where a Creator determines the purposes and means of processing, that Creator may be a separate controller and must provide any privacy information required by law.
1.5. Additional notices may be presented when a particular feature collects or uses personal data in a way that requires more specific information.
2.1. Unless another entity is expressly identified for a particular processing activity, the controller responsible for the processing described in this Privacy Policy is:
Legal entity: Zenlyai OÜ
Trade name: Univerax
Registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Veskiposti tn 2-1002, 10138
https://ariregister.rik.ee/eng/company/17160305, Estonia
Registration number: 17160305
Privacy email: author@univerax.com
Legal email: info@univerax.com
Phone: +90 850 532 23 02
2.2. For privacy questions or requests, contact author@univerax.com.
2.3. For some transactions, a Creator and Univerax may process personal data for different purposes as separate controllers. For example, a Creator may process Customer information to fulfil an order or Booking, while Univerax processes transaction information to operate and secure the Platform.
2.4. If Univerax processes personal data solely on documented instructions from a Creator or another organisation, the relevant organisation may be the controller and Univerax may act as its processor. In that case, privacy requests concerning that processing may need to be directed to the relevant controller.
2.5. Nothing in this Privacy Policy changes the legal roles assigned to the parties by applicable data protection law.
The personal data we collect depends on how you use the Platform, the features you enable, your settings, and the transactions you conduct.
We may collect:
a. name, username, display name, and profile image;
b. date of birth or age information where required;
c. email address, telephone number, and postal address;
d. account credentials and authentication information;
e. preferred language, country, and time zone;
f. account type and user role; and
g. identifiers associated with your account.
If you create a profile or act as a Creator, we may collect:
a. biography, professional title, organisation, and business information;
b. qualifications, expertise, portfolio, work history, and areas of interest;
c. public profile information and profile settings;
d. professional licences, certifications, insurance, or eligibility information;
e. Creator listings, availability, prices, and service areas;
f. tax, invoicing, registration, and VAT information;
g. identity and business-verification information; and
h. payout account information provided to us or our payment partners.
We may collect information about:
a. products, Digital Content, Services, memberships, and Bookings viewed, saved, ordered, licensed, or supplied;
b. order and Booking dates, status, value, currency, and parties;
c. delivery, access, attendance, cancellation, rescheduling, and fulfilment;
d. discounts, referrals, rewards, commissions, taxes, fees, refunds, disputes, and chargebacks;
e. invoices, receipts, and transaction records; and
f. Customer and Creator communications relating to a transaction.
We generally do not receive complete payment card details when those details are collected directly by an independent payment service provider. We may receive payment tokens, limited card information, payment status, and fraud or verification results.
We may process:
a. posts, comments, messages, reviews, ratings, and responses;
b. uploaded text, images, audio, video, files, and other Content;
c. prompts, instructions, source materials, and outputs associated with AI features;
d. Digital Twin configuration, authorised knowledge sources, responses, and interaction records;
e. reports, complaints, appeals, and supporting evidence;
f. support requests and communications with Univerax; and
g. communication preferences and consent records.
Do not provide sensitive or confidential information through public or unnecessary fields.
We may collect information about:
a. users you follow, connect with, block, mute, invite, or interact with;
b. groups, communities, events, or networks you join;
c. reactions, shares, mentions, and other engagement;
d. your selected audience and visibility settings; and
e. connections imported or suggested with your permission.
We will request an appropriate permission before accessing address-book contacts or comparable device data where required by law.
We may automatically collect:
a. IP address and approximate location derived from it;
b. device type, operating system, browser, language, and application version;
c. device, session, cookie, and advertising identifiers where permitted;
d. pages, screens, links, and features viewed or used;
e. searches, clicks, navigation paths, and interaction timestamps;
f. referring pages and campaign information;
g. login, access, error, performance, and diagnostic logs; and
h. security events and suspected abuse indicators.
Cookies and similar technologies are addressed in the Cookies Policy.
We may process:
a. country, region, or approximate location derived from your IP address;
b. location information you add to a profile, listing, delivery address, or Booking; and
c. precise device location only where the feature requires it and you have provided the permission required by law.
You may be able to manage precise location access through your device or Platform settings.
Where appropriate, we may collect:
a. identity-document details and verification results;
b. age, authority, business, sanctions, or eligibility checks;
c. fraud-risk indicators and transaction anomalies;
d. reports concerning unlawful, unsafe, or prohibited conduct;
e. moderation decisions, warnings, restrictions, and appeals;
f. records needed to comply with tax, accounting, consumer, platform, sanctions, or other legal obligations; and
g. communications with authorities or legally authorised third parties.
Where possible, identity documents and biometric verification data may be processed directly by specialist verification providers. We will provide additional information where a verification process involves biometric or other particularly sensitive data.
We may derive or infer information such as:
a. likely interests and content preferences;
b. preferred categories, Creators, products, or Services;
c. relevance or ranking signals;
d. account, transaction, or security risk indicators;
e. likely language or regional preferences; and
f. engagement and performance segments.
We do not treat inferences as certain facts and provide controls or rights concerning profiling where required by law.
The Platform is not intended for the unnecessary collection of special-category or similarly sensitive personal data.
Where a particular Service legitimately requires sensitive personal data, we will process it only where an appropriate legal condition applies and will provide additional information or obtain explicit consent where required.
You must not upload another person’s sensitive personal data unless you are legally authorised to do so and the processing is necessary and proportionate.
We may obtain personal data:
4.1. directly from you when you create an account, complete a profile, conduct a transaction, communicate, or use a feature;
4.2. automatically from your browser, device, and use of the Platform;
4.3. from Customers, Creators, and other users, including through transactions, invitations, messages, tags, reviews, reports, or uploaded Content;
4.4. from payment, identity-verification, fraud-prevention, delivery, analytics, communications, and other service providers;
4.5. from a third-party account or service that you choose to connect;
4.6. from public sources, where collection and use are lawful and reasonably expected;
4.7. from professional advisers, rights holders, regulators, courts, law-enforcement authorities, and other legally authorised parties; and
4.8. through conclusions or inferences generated from the information described above.
If we receive personal data from another source, we will provide the information required by applicable law within the applicable period, unless a lawful exception applies.
We process personal data where necessary to:
a. create, authenticate, and administer accounts;
b. provide profiles, social, network, and communication features;
c. display and distribute Content according to user settings;
d. facilitate orders, licences, Services, and Bookings;
e. process or facilitate payments, refunds, commissions, and payouts;
f. provide Creator tools, dashboards, and analytics;
g. deliver requested AI and Digital Twin features;
h. provide customer support;
i. communicate about accounts and transactions; and
j. enforce the Terms of Use and transaction-specific agreements.
For users protected by the GDPR or comparable laws, the legal basis is generally performance of a contract or taking steps at the user’s request before entering into a contract.
If requested information is necessary to create an account, complete a transaction, or provide a feature, failure to provide it may prevent us from supplying the relevant service.
Where permitted by law, we process personal data for legitimate interests such as:
a. securing the Platform, accounts, users, and transactions;
b. detecting and preventing fraud, misuse, spam, manipulation, and prohibited conduct;
c. moderating Content and enforcing Platform rules;
d. maintaining, troubleshooting, and improving functionality;
e. understanding feature use and Platform performance;
f. providing relevant search results and recommendations;
g. protecting legal rights and resolving disputes;
h. preventing harm and maintaining trust and safety;
i. measuring and improving communications; and
j. developing existing or related services.
Before relying on legitimate interests, we consider the purpose, necessity, reasonable expectations, potential impact, and safeguards. You may object to processing based on legitimate interests as described in Section 14.
We rely on consent where required, including for certain:
a. non-essential cookies and similar technologies;
b. direct marketing communications;
c. precise location access;
d. contact imports or connected-service permissions;
e. uses of sensitive personal data;
f. biometric or identity-related processing; or
g. optional AI, personalisation, or data-use features.
Consent is voluntary and may be withdrawn at any time. Withdrawal does not affect the lawfulness of processing performed before withdrawal.
We process personal data where necessary to comply with legal obligations, including:
a. tax, accounting, invoicing, and financial record requirements;
b. consumer protection and marketplace transparency obligations;
c. sanctions, anti-fraud, anti-money-laundering, or identity requirements where applicable;
d. product, service, and platform safety obligations;
e. lawful requests, court orders, and regulatory duties;
f. data protection and security obligations; and
g. required records of notices, consents, reports, moderation, and complaints.
In exceptional circumstances, we may process personal data to protect a person’s life or physical safety or for a substantial public-interest purpose recognised by applicable law.
6.1. Information you add to a public profile, public listing, review, post, or other public area may be visible to other users, search engines, and the public.
6.2. Depending on your settings and the relevant feature, other users may see information such as your name, username, profile image, biography, professional information, Content, connections, reviews, activity, or Offerings.
6.3. You should review the audience and visibility settings before publishing Content.
6.4. Removing public Content from the Platform does not necessarily remove copies previously indexed, shared, downloaded, or lawfully retained by others.
6.5. Private or restricted visibility reduces the intended audience but cannot guarantee absolute confidentiality.
7.1. When a Customer transacts with a Creator, we may share information reasonably necessary to arrange and fulfil the transaction, such as:
a. name and contact information;
b. order, licence, Service, or Booking details;
c. delivery or attendance information;
d. transaction status;
e. relevant communications; and
f. information required for invoices, legal compliance, or dispute handling.
7.2. Creators may use Customer data only for lawful purposes connected with the transaction or another purpose for which the Customer has received appropriate notice and, where required, provided consent.
7.3. Creators must not use Customer data obtained through Univerax for unrelated marketing, unlawful profiling, data brokerage, or unauthorised disclosure.
7.4. A Creator acting as an independent controller is responsible for its own processing practices. Customers should review any applicable Creator privacy notice before providing information directly to that Creator.
8.1. We may use account, profile, transaction, device, usage, network, and interaction data to:
a. order search results;
b. recommend Content, users, products, Digital Content, Services, or Bookings;
c. personalise feeds and discovery features;
d. estimate interests and relevance;
e. measure Creator and Content performance;
f. detect unusual or harmful activity; and
g. improve Platform functionality.
8.2. Factors may include your stated preferences, searches, interactions, connections, language, approximate location, transaction history, Content relevance, quality indicators, popularity, recency, availability, and policy compliance.
8.3. Personalisation and profiling controls will be provided where required by law or made available as part of the relevant feature.
8.4. Analytics provided to Creators should be aggregated or limited where appropriate. Creators must not use analytics to re-identify individuals, unlawfully discriminate, or infer sensitive characteristics without a valid legal basis.
8.5. More information about recommendation and ranking systems may appear in the Terms of Use and the AI Transparency and Automated Decision Policy.
9.1. Univerax may use AI-assisted systems to support:
a. search, ranking, and recommendations;
b. Content creation, editing, translation, or summarisation;
c. analytics and audience insights;
d. customer support;
e. security, fraud detection, and abuse prevention;
f. Content moderation and report prioritisation; and
g. Digital Twin functions.
9.2. Depending on the feature, AI processing may involve prompts, uploaded Content, interaction history, profile information, feature settings, outputs, and feedback.
9.3. We will provide feature-specific information where an AI function uses personal data in a way not reasonably covered by this Privacy Policy.
9.4. We will not use private User Content to train general-purpose AI models unless we have identified a valid legal basis and provided the information, choices, consent, or objection mechanism required by applicable law.
9.5. Where third-party AI providers process data for a feature, we will apply contractual, security, and data-protection safeguards appropriate to their role.
9.6. Users should not include unnecessary personal data, confidential information, or another person’s sensitive data in AI prompts or source materials.
9.7. AI outputs may contain inaccurate inferences. You may contact author@univerax.com to question or correct personal data attributed to you, subject to applicable law.
10.1. Digital Twin features may process:
a. identity, profile, biography, expertise, and communication preferences;
b. Content and knowledge sources selected or authorised by the user;
c. voice, image, likeness, or other identity elements where enabled;
d. instructions, permissions, configuration, and restrictions;
e. interactions, prompts, responses, and feedback; and
f. security, quality, and performance data.
10.2. A Digital Twin will be configured to operate within the permissions and controls supported by the relevant feature.
10.3. We will obtain consent or another valid legal basis where required for the use of voice, image, likeness, biometric data, or other sensitive identity information.
10.4. A person creating or configuring a Digital Twin using another individual’s data must have all necessary authority, permissions, and legal grounds.
10.5. Where supported, users may review, correct, pause, limit, or delete a Digital Twin and withdraw optional permissions.
10.6. Digital Twin interactions may be logged where necessary for operation, safety, transparency, dispute resolution, and improvement. Retention will be limited in accordance with Section 13.
10.7. Additional information may be provided in the Digital Twin Terms and feature-specific notices.
11.1. Univerax may use automated systems to assist with recommendations, fraud detection, identity checks, security, moderation, transaction review, account integrity, and other Platform operations.
11.2. Many automated systems support or prioritise human decisions and do not independently produce legal or similarly significant effects.
11.3. If we make a decision based solely on automated processing that produces legal effects or similarly significantly affects you, we will do so only where permitted by applicable law.
11.4. Where required, we will provide:
a. notice that automated decision-making is involved;
b. meaningful information about the logic or principal factors involved;
c. information about the significance and expected consequences;
d. measures designed to protect your rights and interests;
e. an opportunity to express your point of view and contest the decision; and
f. access to meaningful human review.
11.5. You may request information or review by contacting author@univerax.com or using the appeal mechanism included in the relevant decision notice.
11.6. We will not use special-category personal data in solely automated significant decisions unless a specific legal condition permits it and suitable safeguards are in place.
We may disclose personal data to the following categories of recipients where necessary and lawful.
We share data between transaction participants as described in Section 7.
Information is shared according to the feature you use and the audience or visibility settings you select.
We may use providers supporting:
a. cloud hosting and data storage;
b. content delivery and technical infrastructure;
c. payment processing and payouts;
d. identity, age, business, or sanctions verification;
e. fraud prevention and security;
f. communications and customer support;
g. analytics and Platform performance;
h. delivery, scheduling, and Booking functions;
i. AI and Digital Twin functionality; and
j. professional, audit, and compliance services.
Service providers may process personal data only for authorised purposes and subject to appropriate contractual and security obligations.
We may disclose information to lawyers, accountants, auditors, insurers, and other professional advisers where reasonably necessary.
We may disclose personal data where we reasonably believe disclosure is necessary to:
a. comply with applicable law, a court order, or a valid legal request;
b. protect rights, safety, security, and property;
c. detect, prevent, or investigate fraud or illegal activity;
d. enforce agreements and Platform rules; or
e. establish, exercise, or defend legal claims.
We assess requests for legal validity and scope where applicable and will not disclose more data than reasonably necessary.
Personal data may be disclosed in connection with a proposed or completed merger, financing, reorganisation, acquisition, sale, transfer, insolvency, or similar transaction. Appropriate confidentiality and data-protection measures will apply.
We may share data when you connect an external service, direct us to disclose information, or provide valid consent.
We may use and disclose information that has been aggregated or de-identified so that it no longer identifies an individual. We will not attempt to re-identify such information except to test our safeguards or as permitted by law.
13.1. We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:
a. provide and secure the Platform;
b. maintain accounts and fulfil transactions;
c. comply with legal, tax, accounting, and regulatory obligations;
d. resolve disputes and enforce agreements;
e. prevent fraud, abuse, and repeated policy violations; and
f. establish, exercise, or defend legal claims.
13.2. Retention periods depend on factors such as:
a. the nature and sensitivity of the data;
b. the duration of the account or transaction relationship;
c. user settings and deletion requests;
d. limitation periods and potential disputes;
e. security and fraud-prevention needs;
f. legal recordkeeping duties; and
g. technical backup cycles.
13.3. When personal data is no longer required, we will delete, anonymise, or securely isolate it, subject to lawful exceptions.
13.4. Account closure does not necessarily result in the immediate deletion of all information. Transaction records, consent records, security logs, moderation evidence, financial documents, and legal records may need to be retained.
13.5. Content shared with other users may remain available to them where they have independently stored it or where continued availability is necessary to fulfil a transaction or licence.
13.6. Backup copies may remain for a limited period until overwritten or securely removed and will remain protected while retained.
13.7. Further information may be provided in the Data Retention and Deletion Policy.
Depending on where you live and the law that applies, you may have the right to:
14.1. receive information about how your personal data is processed;
14.2. obtain confirmation that we process your personal data and request access to it;
14.3. correct inaccurate or incomplete personal data;
14.4. request deletion of personal data;
14.5. restrict particular processing;
14.6. object to processing based on legitimate interests or a public-interest ground;
14.7. object at any time to direct marketing;
14.8. receive certain personal data in a structured, commonly used, machine-readable format and transmit it to another controller;
14.9. withdraw consent at any time where processing is based on consent;
14.10. request safeguards concerning qualifying automated decisions, including human intervention and an opportunity to contest the decision;
14.11. lodge a complaint with a competent data protection or supervisory authority; and
14.12. exercise any additional rights provided by applicable law.
These rights are not absolute. A request may be limited where an applicable legal exception applies, including where processing is necessary to protect another person’s rights, comply with law, or establish, exercise, or defend legal claims.
15.1. You may use available account controls or contact author@univerax.com.
15.2. Your request should clearly describe the right you wish to exercise and the personal data concerned.
15.3. We may request information reasonably necessary to verify your identity and authority. We will not request more verification data than reasonably required.
15.4. An authorised representative may submit a request where permitted by law. We may request evidence of that authority and, where appropriate, verify the request directly with you.
15.5. We will respond within the period required by applicable law. If a lawful extension is necessary, we will notify you and explain the reason.
15.6. Requests are generally handled without charge. A reasonable fee may be charged, or action may be refused, only where permitted by law, including for manifestly unfounded or excessive requests.
15.7. If we decline a request, we will explain the reason and identify available complaint or appeal rights where required.
16.1. We may send essential account, transaction, security, policy, and service communications without treating them as marketing.
16.2. We send electronic direct marketing only where we have the consent or other legal basis required by applicable law.
16.3. You may opt out of marketing by:
a. using the unsubscribe mechanism in the communication;
b. changing available communication settings; or
c. contacting author@univerax.com.
16.4. Opting out of marketing does not stop essential service or transaction communications.
16.5. Creators may not use Customer data obtained through Univerax for unrelated direct marketing without satisfying all applicable notice, consent, and opt-out requirements.
17.1. We may use cookies, local storage, pixels, software development kits, and similar technologies to:
a. operate and secure the Platform;
b. remember settings and preferences;
c. understand use and performance;
d. personalise Content and recommendations; and
e. support advertising or campaign measurement where permitted.
17.2. Where required by law, non-essential technologies will not be used until the required consent has been obtained.
17.3. You may manage available choices through the cookie preference tool and your browser or device settings.
17.4. Further information is provided in the Cookies Policy.
18.1. Univerax and its service providers may process personal data in countries other than the country where you live.
18.2. Where personal data protected by the GDPR or comparable law is transferred outside the European Economic Area or another protected jurisdiction, we will use a recognised transfer mechanism where required, such as:
a. an adequacy decision;
b. approved standard contractual clauses;
c. binding corporate rules where applicable;
d. an approved certification or code mechanism where available; or
e. a legally permitted derogation for a specific situation.
18.3. Where appropriate, we assess whether supplementary contractual, technical, or organisational measures are needed to protect transferred data.
18.4. You may contact author@univerax.com for information about the safeguards relevant to your personal data, subject to lawful confidentiality restrictions.
19.1. We use technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and accidental loss, destruction, alteration, or disclosure.
19.2. Measures may include, as appropriate:
a. access controls and authentication;
b. encryption in transit and, where appropriate, at rest;
c. logging, monitoring, and threat detection;
d. vulnerability and security management;
e. provider assessment and contractual controls;
f. backup and recovery measures;
g. staff confidentiality and access restrictions; and
h. incident response procedures.
19.3. No online service or storage system can guarantee absolute security. You are responsible for protecting your credentials and promptly reporting suspected unauthorised access.
19.4. Where a personal data breach is likely to create a legally relevant risk, we will notify the competent authority and affected individuals as required by applicable law.
20.1. The Platform is not intended for children to create independent accounts, conduct transactions, act as Creators, receive payouts, or use adult-oriented features unless the Platform expressly supports the relevant age group and legally valid authorisation is in place.
20.2. We do not knowingly collect personal data from a child in a manner prohibited by applicable law.
20.3. Where consent is the legal basis for an online service offered directly to a child, we will obtain parental or guardian authorisation where required by the law that applies.
20.4. Age thresholds and parental-authorisation requirements vary by country. A feature-specific notice may apply where Univerax offers functionality suitable for minors.
20.5. If you believe that a child has provided personal data unlawfully or is at risk, contact author@univerax.com or support@univerax.com.
20.6. We may restrict or remove an account or Content while assessing an age or child-safety concern.
21.1. The Platform may contain links to or integrations with third-party websites, payment services, social networks, applications, or tools.
21.2. If you choose to use a third-party service, that third party may process your personal data under its own privacy policy.
21.3. This Privacy Policy does not govern independent third-party processing. You should review the relevant third party’s privacy information before using its service.
22.1. We may update this Privacy Policy to reflect changes in law, technology, Platform functions, data practices, or organisational arrangements.
22.2. We will publish the updated version and identify its effective date.
22.3. If a change materially affects your rights or how we use personal data, we will provide additional notice where required by law.
22.4. Where consent is required for a new purpose, we will request consent before beginning that processing.
23.1. If you have a concern about our processing of personal data, please contact author@univerax.com so that we can investigate.
23.2. You may also lodge a complaint with the data protection or supervisory authority competent for your habitual residence, place of work, or the location of the alleged infringement, where applicable.
23.3. Contacting us first does not limit your right to approach a supervisory authority or court.
Privacy questions, rights requests, and complaints may be directed to:
Legal entity: Zenlyai OÜ
Trade name: Univerax
Registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Veskiposti tn 2-1002, 10138
https://ariregister.rik.ee/eng/company/17160305, Estonia
Registration number: 17160305
Privacy email: author@univerax.com
Legal email: info@univerax.com
Support email: support@univerax.com
Phone: +90 850 532 23 02