Privacy Policy

1. Introduction

This Privacy Policy explains how Lore Labs AG ("Lore Labs," "we," "us," or "our") collects, uses, and protects personal data when you use our CONTXT platform ("Platform" or "Service") accessible at https://contxt.art and related services.

We are committed to protecting your privacy and handling your personal data in accordance with applicable data protection laws, including the Swiss Federal Act on Data Protection (FADP) and the European General Data Protection Regulation (GDPR).

2. Data Controller

3. Data We Collect

4. How We Use Your Data

5. Legal Basis for Processing

We process your personal data based on the following legal grounds:

6. Data Sharing and Disclosure

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside Switzerland and the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where applicable
• Other legally recognized transfer mechanisms

Our primary infrastructure is hosted in the European Union (Hetzner, Germany), and we prioritize keeping data within the EU/EEA where possible.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy:

9. Your Rights

Under applicable data protection laws, you have the following rights:

• Access: Request a copy of your personal data we hold.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data ("right to be forgotten").
• Restriction: Request limitation of processing in certain circumstances.
• Portability: Receive your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Withdraw Consent: Withdraw consent at any time where processing is based on consent.

To exercise these rights, please contact us at [email protected]. We will respond to your request within 30 days.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Access controls and authentication requirements
• Regular security assessments and monitoring
• Employee training on data protection practices

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your session and authentication state
• Remember your preferences and settings
• Analyze platform usage and performance
• Provide security features

Types of Cookies:

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may affect platform functionality.

12. Children's Privacy

CONTXT is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13, we will take steps to delete such information.

Institutions may create child-friendly AI voices with simplified language, but visitors under 13 should use the platform under parental supervision.

13. AI and Automated Processing

CONTXT uses artificial intelligence to provide conversational experiences about artworks and exhibitions. This involves:

• Processing your messages to generate relevant responses
• Analyzing uploaded images for artwork recognition
• Generating personalized suggestions and themes

Important Notes:

• AI responses are grounded in institution-provided content
• We may use fully anonymized and aggregated conversation data to improve our AI systems, but your personal conversations are never used in identifiable form for training purposes
• You can flag AI responses for review if you believe they are inaccurate or inappropriate

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending email notification for significant changes (registered users)

We encourage you to review this policy periodically.

15. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

Supervisory Authority:

If you are unsatisfied with our response, you have the right to lodge a complaint with the relevant data protection authority:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC)
• EU/EEA: Your local supervisory authority

16. Additional Information for Swiss Residents

As a Swiss company, we comply with the Swiss Federal Act on Data Protection (FADP). Swiss residents have additional rights under the FADP, including the right to information about the processing of personal data and the right to data portability.

17. Additional Information for EU/EEA Residents

If you are located in the European Union or European Economic Area, you have additional rights under the GDPR. Lore Labs AG acts as the data controller for your personal data. For the purposes of GDPR compliance, our legal basis for processing is as outlined in Section 5 above.