Privacy & Cookie Policy

We inform all users that the website recomind.io is property of Iron Intelligent Technologies LLC, a United States company operating under the RecoMind brand (the Owner), responsible for the treatment of personal data. This policy is issued in accordance with the privacy laws applicable to us in the United States, including, where applicable, the California Consumer Privacy Act as amended by the California Privacy Rights Act, and, for users located outside the United States, with Regulation (EU) 2016/679 (GDPR) in the European Economic Area and the United Kingdom, with the Brazilian General Data Protection Law (Lei 13.709/2018, LGPD), and with equivalent data protection laws elsewhere in the Americas. We have adopted every security measure legally required for data protection and the protection of the privacy of users.

Where processing is based on consent, that consent is requested before the processing begins and may be withdrawn at any time, without affecting the lawfulness of the processing carried out before the withdrawal.

Confidentiality and security are priority values for RecoMind. We assume the commitment of guaranteeing the privacy of the user at every moment and of not gathering unnecessary information.

Owner and Data Controller

Iron Intelligent Technologies LLC, a limited liability company formed under the laws of the State of Wyoming, United States, operating under the RecoMind brand.

30 N Gould St, Ste R, Sheridan, Wyoming 82801, United States.

Owner contact email: info@recomind.io

Data Protection Officer

The Owner has designated a data protection contact, acting as Data Protection Officer under the GDPR and as Encarregado pelo Tratamento de Dados Pessoais under art. 41 of the LGPD, and serving as the privacy contact for Users in the United States and in the rest of the Americas:

Dr. Miguel Gonzalez-Fierro, info@recomind.io

Types of Data Collected

Among the types of Personal Data that this website collects, by itself or through third parties, there are: Cookies, Usage Data, and email address.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this website. Data marked as required in our forms is necessary to provide the service requested, and failure to provide it may make it impossible for us to deliver that service. Any other Data is optional.

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

Personal Data Processed Through the RecoMind Platform

The sections above describe the Data collected through this website. Separately, RecoMind provides a personalization platform to business clients (merchants). When we process personal data on behalf of a merchant, the merchant is the data controller and RecoMind acts solely on their behalf: as a service provider under United States privacy law, as a data processor under art. 28 of the GDPR, and as operador under the LGPD. We process that data only on the merchant's documented instructions and under a Data Processing Agreement.

In that role we process product catalog data together with pseudonymous shopper identifiers and behavioral events such as searches, product views, clicks, cart additions, and purchases. We do not require names, postal addresses, or payment details to deliver the service. Each merchant's data is isolated by tenant, is never combined with the data of another merchant, and is never used to train models shared across merchants.

Shoppers who wish to exercise their rights in respect of this processing should contact the merchant whose store they used, as that merchant is the data controller. We assist merchants in fulfilling those requests within the applicable legal deadlines.

Automated Decision-Making and Profiling

The RecoMind platform builds preference profiles from behavioral data in order to rank search results and recommend products. This profiling affects only the selection and ordering of the content shown to a shopper. It does not produce legal effects or similarly significant effects on any individual, and no decision concerning a person is taken solely by automated means. Where a shopper has not given consent, personalization is disabled and results are contextual only.

Legal Basis of Processing

Under United States privacy law, processing is based on the notice given in this policy, on the performance of our agreement with the User, and, where required by law, on the User's consent.

Under the GDPR and the LGPD, the Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes;
  • Provision of Data is necessary for the performance of an agreement with the User;
  • Processing is necessary for compliance with a legal obligation;
  • Processing is related to a task carried out in the public interest;
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner.

Your Rights

We grant the rights below to every User, wherever they are located, rather than limiting them to the residents of a particular jurisdiction. Users in the United States, in California in particular, have the rights to know, to delete, to correct, to opt out of the sale or sharing of personal information, and not to be discriminated against for exercising them. We do not sell personal information, and we do not share it for cross-context behavioral advertising.

Users have the following rights regarding their personal data:

  • Right of Non-Discrimination: Receive the same service and price when you exercise any of these rights;
  • Right of Access: Access your information at any moment;
  • Right of Rectification: Modify any data which is incorrect;
  • Right of Objection: Object to any treatment you consider inadequate;
  • Right of Erasure: Request deletion of your data;
  • Right to be Forgotten: Have your data deleted when you cancel the service;
  • Right of Limiting Treatment: Limit the treatment of your data;
  • Right of Data Portability: Receive your data in a portable format;
  • Right to Withdraw Consent: Withdraw your consent at any time where processing is based on consent;
  • Right to Lodge a Complaint: File a complaint with the competent authority in your place of residence. In the United States this is your state attorney general, or the California Privacy Protection Agency for California residents. In the European Economic Area and the United Kingdom it is your national supervisory authority. In Brazil it is the Autoridade Nacional de Proteção de Dados (ANPD).

Recipients and Sub-Processors

We do not sell personal data and we do not share it for advertising purposes. Data is disclosed only to the service providers required to operate this website and the RecoMind platform. Each of them is bound by a data processing agreement and processes data solely on our instructions:

  • Cloud infrastructure providers: hosting, computation, storage, managed databases, secrets management, and the delivery of transactional email. We currently rely on DigitalOcean, Amazon Web Services, Microsoft, and Google for these services.
  • Artificial intelligence model providers: generation of conversational assistant responses and related model inference. We currently rely on Anthropic, OpenAI, and Microsoft for these services. Data sent to these providers is not used to train their models.
  • Payment and billing providers: subscription billing, invoicing, and payment processing. We currently rely on Stripe for these services.

Providers are listed by the category of service they supply to us, since the specific services we use within a category may change over time. Personal data may also be disclosed where required by law or by a competent authority. This list is kept up to date, and we notify our business clients of any material change to it.

Place of Processing

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.

The Owner is established in the United States, and Data is processed in the United States and in the European Union. Where personal data leaves the European Economic Area or the United Kingdom, or leaves Brazil or another country in the Americas whose law restricts such transfers, the transfer is governed by the European Commission's Standard Contractual Clauses or by an equivalent safeguard recognised under Chapter V of the GDPR and art. 33 of the LGPD, together with the technical and organizational measures described in this policy.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Personal Data collected for purposes related to the performance of a contract shall be retained until such contract has been fully performed.

For the RecoMind platform, behavioral and interaction data is retained according to the merchant's subscription plan: 90 days on the Starter plan, 365 days on the Pro and Growth plans, and a period defined in the contract for Enterprise clients. Catalog data is retained only while the merchant's account is active. These limits are enforced by an automated daily job that permanently deletes records once their retention period has expired. On termination of a contract, the personal data of that merchant is deleted from our production systems.

Cookies

Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the owners of the site.

Types of Cookies We Use

Essential Cookies: These cookies are necessary for the website to function properly. They enable basic functions like page navigation and access to secure areas.

Analytics Cookies: This website does not currently set analytics or advertising cookies. If we introduce them, they will only be placed after you have given your prior consent, and you will be able to withdraw that consent at any time.

Information Collected via Cookies

Where analytics cookies are used with your consent, they allow us to collect information such as:

  • The number of users accessing the website
  • The number of pages viewed
  • The frequency and duration of visits
  • The browser and device used
  • General geographic location

Managing Cookies

You can restrict, block or delete cookies using your browser settings. In each browser the operation is different - the "Help" function will show you how to do it. Here are links for popular browsers:

Analytics

This website does not currently use third-party analytics services. Should we adopt one, this policy will be updated to identify the provider before the service is enabled, and analytics cookies will be placed only after you have given your consent.

Hosting

This website uses hosting services to host Data and files that enable this website to run and be distributed. These services may collect log data and other usage information.

How to Exercise Your Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests are free of charge and are addressed as early as possible, and in any case within the deadline that applies to the User: 45 days for residents of the United States, one month for the European Economic Area and the United Kingdom, and 15 days for Brazil. We may ask for information reasonably necessary to verify the identity of the person making the request before we act on it.

Changes to This Policy

The Owner reserves the right to make changes to this privacy and cookie policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Legal Information

This privacy statement has been prepared based on the provisions of multiple legislations, including United States federal and state privacy law, Art. 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation), and the Brazilian General Data Protection Law (Lei 13.709/2018).

Contact

For any questions regarding this Policy, please contact us at: info@recomind.io

Last updated: August 2026