Privacy Notice

⚠️ PREVIEW DRAFT — under legal review. This document is a good-faith draft pending review by qualified legal counsel. By using Tokonomix you agree to these provisions as a binding contract; substantial changes will be communicated by email and accompanied by a version bump. Last updated: 2026-06-01.

Privacy Notice

This Privacy Notice explains how Tokonomix processes personal data when you visit our website, create an account, or use the Tokonomix API. It is issued in compliance with Regulation (EU) 2016/679 (the "GDPR") and the Dutch Implementation Act (UAVG).

1. Controller

The controller of your personal data is:

InterIP Networks B.V. (trading as Tokonomix) Registered office: Linnewever 18, 2292 JH Wateringen, the Netherlands. Chamber of Commerce (KvK): 27183782 VAT identification number: NL813181811B01 General contact: support@tokonomix.ai Privacy contact: privacy@tokonomix.ai

2. Data Protection Officer

You can reach our Data Protection Officer at dpo@tokonomix.ai. The DPO mailbox is monitored on business days; responses to formal subject-rights requests are issued within the GDPR statutory one-month period (Art. 12(3) GDPR).

Operational note: the DPO mailbox is being provisioned during the preview period. Until provisioning completes, requests sent to this address are auto-forwarded to privacy@tokonomix.ai — no messages are lost.

3. Purposes & Lawful Basis

We process personal data for the purposes set out below. The lawful bases relied on are listed alongside each purpose pursuant to Article 6(1) GDPR.

• Creating and authenticating your account — Contract, Art. 6(1)(b).
• Routing API calls and metering Credit consumption — Contract, Art. 6(1)(b).
• Processing payments via Mollie B.V. — Contract, Art. 6(1)(b).
• Detecting fraud, abuse, and account stuffing — Legitimate interest, Art. 6(1)(f).
• Complying with tax, accounting, and anti-money-laundering law — Legal obligation, Art. 6(1)(c).
• Sending product announcements and editorial updates — Consent, Art. 6(1)(a).
• Analytics and performance measurement (if you opt in) — Consent, Art. 6(1)(a).

Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

4. Categories of Personal Data

We process the following categories of personal data:

• Identification data — full name, email address, account preferences;
• Authentication data — salted password hashes, second-factor secrets encrypted at rest, recovery-code hashes;
• Billing data — VAT number, company name, billing address, payment-token references issued by Mollie (we do not store full card or bank-account numbers);
• Usage data — API requests, model selections, token counts, latency measurements, response status codes, derived cost figures;
• Technical data — IP address, user-agent string, browser-language header, session cookie identifiers;
• Communication data — content of support and abuse-report tickets;
• Abuse-investigation data — in the two situations described below, and to protect the service against fraud and automated abuse, the content of the requests sent from an account. We store the text of each message (clipped to the first 2 000 characters, and at most 50 messages per request), the number of messages, the untruncated total length, the models requested, the request identifier, the originating IP address and the user-agent string. Attached images are recorded only as a placeholder, never the image itself. We apply this in two situations, and in no others. First, to individually designated accounts under an active investigation, for as long as that investigation runs. Second, to every new account during a short first-use window: approximately its first twenty (20) requests within seven (7) days of sign-up, whichever limit is reached first, after which the capture ends by itself and is not resumed unless the account is individually designated. Established accounts outside such a designation are not captured at all. Our lawful basis is our legitimate interest in preventing fraud against, and abuse of, the service (Article 6(1)(f) GDPR); we have carried out a balancing test and record it with each designation. You may object under Article 21, and we will stop unless we can demonstrate compelling legitimate grounds — in an active fraud investigation we may be able to.

If you send another person's personal data inside a prompt, we normally handle it strictly on your instructions as your processor. Where such a prompt is captured under an abuse investigation, we process that content for our own purpose and are the controller for it. This is one more reason not to place other people's personal data — and never special categories of it — in prompts.

We do not knowingly process special categories of personal data under Article 9 GDPR; you should not submit such data through prompts.

5. Recipients & Sub-processors

We disclose personal data only to the recipients and sub-processors listed below, all of whom are bound by data-processing agreements compliant with Article 28 GDPR.

• Mollie B.V. — Payment processing — Netherlands (EEA).
• Anthropic, PBC — LLM inference (Claude family) — United States.
• OpenAI, OpCo LLC — LLM inference (GPT family) — United States.
• Google LLC — LLM inference (Gemini family) — United States.
• OVH Groupe SAS — LLM inference and infrastructure — France (EEA).
• Hetzner Online GmbH — Infrastructure hosting — Germany (EEA).
• InterIP Networks BV — Infrastructure operations and support — Netherlands (EEA).

Our up-to-date sub-processor list is maintained at /en/legal/sub-processors. We notify Customers by email of changes at least fifteen (15) days before a new sub-processor becomes operational, and you may object on legitimate grounds.

6. Retention

We retain personal data only for as long as necessary to achieve the purpose for which it was collected:

• Account profile — for the lifetime of the account plus thirty (30) days after termination, after which we delete or pseudonymize the profile;
• Billing records and invoices — seven (7) years from the end of the fiscal year of issue, as required by Article 52 of the Dutch State Taxes Act (Algemene wet inzake rijksbelastingen);
• API usage logs — ninety (90) days from the request timestamp, after which aggregate statistics are retained but raw rows are deleted;
• Audit and abuse-detection logs — one (1) year from the event;
• Abuse-investigation request content — thirty (30) days from the request, removed by an automated hourly sweep, unless a longer period is necessary to establish, exercise or defend a legal claim;
• Support and abuse-report communications — three (3) years from the last interaction, unless a longer retention is required to defend a legal claim.

After the applicable retention period elapses, data is deleted from primary storage and rotated out of backups on the next backup-retention cycle (no later than thirty days).

7. Your Rights

Subject to the conditions set out in the GDPR, you have the right to:

• Access — obtain a copy of the personal data we hold about you (Art. 15);
• Rectification — correct inaccurate or incomplete data (Art. 16);
• Erasure — request deletion of data we are no longer entitled to keep (Art. 17);
• Restriction — request that we limit processing in defined situations (Art. 18);
• Portability — receive a machine-readable export of data you provided to us under a contract (Art. 20);
• Object — object to processing based on legitimate interest (Art. 21).

You can exercise these rights by writing to privacy@tokonomix.ai from the email address associated with your account. We will respond within one month of receipt; where requests are complex we may extend by two further months and will inform you of the extension.

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement. The Dutch supervisory authority is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).

8. International Transfers

Several of our sub-processors are located outside the European Economic Area, in particular Anthropic PBC, OpenAI OpCo LLC, and Google LLC in the United States. Personal data transferred to these recipients is protected by:

• the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), incorporated by reference into the relevant data-processing agreement;
• where applicable, the recipient's certification under the EU-US Data Privacy Framework;
• transfer-impact assessments and, where appropriate, supplementary technical measures such as encryption in transit and at rest.

You may request a copy of the SCCs covering a specific transfer by writing to privacy@tokonomix.ai.

9. Cookies

We rely on the smallest possible cookie footprint:

• Strictly necessary cookies — a session-cookie that holds your authentication token after sign-in, plus a CSRF-protection token. These cookies cannot be refused without disabling the Service.
• Analytics cookies — set only after you give explicit consent through our cookie banner. They allow us to measure aggregate site usage and improve content.
• Marketing cookies — currently not set; this category is reserved for future opt-in attribution use.

You can change your cookie preferences at any time via the link in the footer of every page. Consent records are stored for one year.

10. Children

The Service is not directed at children under the age of sixteen (16). We do not knowingly collect personal data from a person under that age. If you believe a child has provided personal data to us, please contact privacy@tokonomix.ai and we will delete the data without undue delay.

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Changes to this Notice. We may update this Privacy Notice from time to time. When changes are material we will bump the version number, refresh the "last updated" date, and notify active Customers by email at least fourteen (14) days before the change takes effect. The version history is available on request.