Last Updated: August 27, 2026

This Privacy Policy governs the processing of Personal Data by ZugCat Enterprises LLC ("Company," "we," "us," or "our") across our websites, technical advisory platforms, client portals, and enterprise AI tools (collectively, the "Service").

ZugCat Enterprises LLC is a trust-first security and technical advisory firm. We employ strict Zero-Data-Retention (ZDR)architectures across all artificial intelligence and machine learning workflows. We do not use client-specific data, proprietary source code, or personally identifiable information (PII) to train public or private AI models.

1. Zero-Retention AI Infrastructure & Technical Safeguards

While standard business operations— including processing of Account & Contact Data, Transaction Data, and Technical Telemetry—are maintained under dedicated data retention schedules pursuant to applicable legal requirements, our artificial intelligence and machine learning workflows adhere to the following strict technical parameters:

• Stateless API Processing: All client assets, code snippets, and advisory inputs submitted through artificial intelligence workflows are processed strictly via enterprise-grade APIs configured for stateless processing.

• Transient Memory: Processing occurs exclusively in transient, volatile memory and is flushed immediately post-execution.

• Zero Model Retraining & Abuse Logging Exemptions: No client-submitted inputs or generated outputs are logged, stored at rest, or used by third-party model providers (e.g., OpenAI, Anthropic, AWS Bedrock) for model training or refinement. Furthermore, all vendor processing agreements explicitly exempt client data from third-party human review and standard vendor abuse monitoring logs.

• Ephemeral Caching: Any session caching necessary for user interface performance is end-to-end encrypted, logically isolated per client, and automatically purged upon session termination or user logout.

2. Scope & Definitions

For the purposes of this Privacy Policy:

• Account: A unique account created for you to access our Service or specific features.

• Company / Data Controller: ZugCat Enterprises LLC, 156 N Wolcott St, Ste 133, Casper, WY 82001. For the purpose of the EU General Data Protection Regulation (GDPR), the Company acts as the Data Controller.

• Personal Data / Personal Information: Any information that identifies, relates to, or isreasonably linkable to an identified or identifiable natural person or household (under GDPR,CCPA/CPRA, and applicable US state privacy laws).

• Service: Refers to our primary web domain, client portals, and technical advisory platforms accessible via zugcat.com.

• Service Provider / Data Processor: Vetted third-party vendor entities operating under signed Data Processing Agreements (DPAs). For those vendors, they act as the data controllers and own the responsibility.

3. Data Categories, Usages & Lawful Bases

A. Data You Provide Directly

• Category: Account & Contact

  • Description: Name, business email address, phone number, and enterprise login credentials
  • Lawful Basis for Processing: Contract Performance / Legitimate Interest

• Category: Transaction Data

  • Description: Invoicing records and payment status(processed via Stripe; no full card numbers stored).
  • Lawful Basis for Processing: Contract Performance / Statutory Legal Compliance

• Category: Technical Telemetry

  • Description: IP addresses, system diagnostics, browser types, and interaction metrics.
  • Lawful Basis for Processing: Legitimate Interest (Security & System Integrity)

• Category: Cookies & Analytics

  • Description: Mandatory authentication cookies and pseudonymized web analytics (public site only).
  • Lawful Basis for Processing: Consent / Essential Technical Functionality

B. Technical Safeguards & Retention

When accessing the Service, we automatically collect telemetry data (such as IP addresses, system diagnostics, device identifiers, and page interaction metrics). This data is processed strictly as necessary to ensure system security, monitor infrastructure performance, and comply with legal or tax recordkeeping requirements. Non-AI Personal Data, including Transaction Data and invoicing history, is retained strictly according to Section 4 below.

C. Tracking Technologies & Cookies

We utilize necessary, functionality, and limited performance cookies to administer the Service:

• Essential Cookies: Mandatory session cookies required for authentication and security routing.

• Functionality Cookies: Persistent cookies used to remember user preferences (e.g., region or theme settings).

• Analytics Cookies: Pseudonymized web analytics run exclusively on public marketing pages to measure site traffic. Analytics tracking is completely isolated from client portals and AI input interfaces.

D. Third-Party Sub-processors & AI Training Prohibitions

We engage trusted third-party service providers to facilitate infrastructure, communication, and payment workflows. Payment transactions and invoicing records are processed via Stripe; ZugCat Enterprises LLC does not store full credit card numbers or sensitive payment credentials on internal systems.

Explicit Model Training Prohibition: ZugCat Enterprises LLC does not sell, license, or process client-provided PII, source code, or telemetry to train, retrain, or fine-tune first-party or third-party AI/ML models.

4. Data Retention Lifecycle & Purging Schedule

ZugCat Enterprises LLC retains Personal Data only for as long as necessary to fulfill operational, advisory, or legal requirements. Data is permanently purged or anonymized according to the following schedule:

• AI Session Inputs/Outputs: Flushed immediately from transient memory post-execution; temporary interface session cache is purged automatically upon log-out.

• Account & Communications Data: Retained for the active duration of the client relationship plus three (3) years for audit and legal compliance requirements.

• Billing & Financial Records: Retained for seven (7) years to comply with statutory tax and financial accounting regulations.

• Technical Diagnostic Logs: Automatically rotated and permanently destroyed on a rolling 90-day cycle

5. Disclosures, Cross-Border Transfers & State Rights

• No Sale or Commercial Sharing: ZugCat Enterprises LLC does not sell, rent, or trade Personal Data or client inputs. We have not sold or shared (for cross-context behavioral advertising) any Personal Data in the preceding 12 months. We actively recognize and honor Global Privacy Control (GPC) opt-out signals transmitted by web browsers.

• Vetted Service Providers: Third-party data processors (such as hosting, telemetry, or payment providers) access limited data strictly under signed Data Processing Agreements (DPAs) containing mandatory technical and administrative security requirements.

• International Data Transfers: Transfers of Personal Data originating from the European Economic Area (EEA), United Kingdom, or Switzerland to jurisdictions without equivalent data protection laws are conducted using European Commission-approved Standard Contractual Clauses (SCCs) or the EU-U.S. Data Privacy Framework

6. Your Global Privacy Rights

Depending on your jurisdiction (including the EU/UK under GDPR, and US states such as California, Colorado, Connecticut, Indiana, Utah, and Virginia), you hold the following statutory rights over your Personal Data:

Core Privacy Rights:

• Access & Portability: Request details regarding the categories of Personal Data we maintain and obtain a machine-readable copy.

• Correction & Erasure: Request the correction of inaccurate data or the permanent deletion of Personal Data ("Right to be Forgotten").

• Opt-Out & Restriction: Limit processing of sensitive personal data, restrict automated processing, or opt out of direct marketing.

• Non-Discrimination: ZugCat Enterprises LLC will never discriminate against you for exercising your legal privacy rights.

Request Response Timelines & Verification:

We will acknowledge your privacy request within 10 business days and deliver a substantive response within 30 days (GDPR/UK) or 45 days (US state privacy laws). Identity verification may be required prior to processing sensitive requests.

Right to Appeal:

If we decline to take action on your request, you have the right to appeal our decision within 30 days of receiving our response. Instructions on how to initiate an appeal will be provided in our decision notice.

Right to Lodge a Complaint:

Individuals residing in the EEA or UK have the right to lodge a complaint directly with their local Supervisory Authority (Data Protection Authority).

Automated Decision-Making & Human Oversight:

ZugCat Enterprises LLC does not utilize automated decision-making or profiling algorithms to make automated choices that produce legal or similarly significant effects. All AI tools deployed within our advisory workflows function as decision-support systems subject to mandatory Human-in-the-Loop (HITL) review.

To exercise any of your privacy rights, please contact our Data Protection Office at info@zugcat.com.

7. Security & Information Protection

• Data Security: We enforce ro bust administrative, technical, and physical safeguards— including end-to-end encryption for data in transit (TLS 1.3) and at rest (AES-256)—to shield personal data against unauthorized access, disclosure, or alteration.

• Retention Limits: Administrative Personal Data is retained strictly in accordance with Section 4 and purged automatically upon reaching the end of its lifecycle schedule.

8. Updates & Contact Information

We reserve the right to modify this Privacy Policy at any time.Material updates will becommunicated by revising the "Last Updated" date above and issuing an administrative notice via email or platform notification.

If you have questions, feedback, or concerns regarding our privacy practices, please reach out to us at:

Email: info@zugcat.com

Entity: ZugCat Enterprises LLC

Address: 156 N Wolcott St, Ste 133, Casper, WY 82001