Privacy Policy

Last Updated: 2026/5/25 15:24 UTC

This Privacy Policy explains how the founders of ExactlyX.com ("we", "our", or "us") collect, use, and protect your personal data when you use our closed beta 3D kitchen modeling platform and related services (the "Platform"), whether you are a registered user or a guest using trial features.

Note: ExactlyX is currently operating in a pre-incorporation closed beta phase. Upon formal incorporation as a legal entity, this policy will be updated to reflect the registered company details.

1. Data Controller

During this beta phase, the data controller responsible for your personal data under the General Data Protection Regulation (GDPR) is:

• Operating Brand: ExactlyX.com

• Representative: Didzis Solims

• Contact Email: hi@exactlyx.com

2. The Data We Collect and Why We Process It

We limit data collection to what is strictly necessary to provide the Platform's core services and improve your experience.

• Guest & Session Data: We collect your IP address, session tokens, and trial usage metrics when you use the platform as an unregistered user.

  • Legal Basis: Legitimate Interest to provide temporary access, prevent abuse of free tokens, and ensure platform security.

• Account Data: We collect your email address, name when you register.

  • Legal Basis: Performance of a Contract to create your account and manage your access.

• Service Marketing Data: We collect your email address to send you updates and offers directly related to our 3D modeling software. You can opt out at any time.

  • Legal Basis: Legitimate Interest to keep our users informed about product updates and relevant services.

• Project & Spatial Data: We collect your kitchen dimensions, wall configurations, appliances, and hosted 3D models.

  • Legal Basis: Performance of a Contract to generate, render, and securely host your kitchen designs.

• Interaction & Collaboration Data: We collect text inputs, uploaded files, and user interactions within the Platform.

  • Legal Basis: Performance of a Contract to facilitate the creation of the 3D model and enable project collaboration.

3. Platform AI and Service Improvement

Our Platform utilizes Artificial Intelligence (AI) to generate models and assist users.

• Service Optimization: We analyze user interactions, session data, and technical metadata to troubleshoot issues, optimize system logic, and drive feature development. This is done under our Legitimate Interest to provide a functional and continuously improving product.

• No Public Model Training: We do not use your personal data, interaction logs, or spatial designs to train publicly accessible AI models.

4. How We Share Your Data

We do not sell your data. We only share your data under the following legal frameworks:

• User-Initiated Sharing: When you generate a model link and share it, you explicitly authorize anyone with that link to view the 3D model and participate in the associated project collaboration.

• Third-Party Processors & Technology Partners: We use secure, enterprise-grade third-party service providers to host our cloud infrastructure and power our AI capabilities. We reserve the right to change infrastructure providers at any time to ensure the best service. All providers act strictly as our "Data Processors" and are bound by Data Processing Agreements (DPAs) that prohibit them from using your data for their own independent purposes.

• Legal Obligations: We may disclose data if required by regulatory authorities under applicable laws.

5. Data Location and International Transfers

• Primary Infrastructure: Your personal data, spatial kitchen designs, and 3D models are securely hosted and stored on servers located within the European Union (Germany, via Hetzner).

• AI and Third-Party Routing: While our primary databases remain in the EU, processing certain user inputs via third-party AI engines or other integrated services may occasionally involve routing data through or storing data in countries outside the European Economic Area (EEA), such as the United States.

• Safeguards: For any data processed outside the EEA, we ensure strict compliance with GDPR Chapter V by utilizing legally approved safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission, or relying on recognized adequacy decisions (such as the EU-US Data Privacy Framework).

6. Children's Privacy

Our Platform is designed primarily for professionals and adults. We do not knowingly collect personal data from children under the age of 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us so we can delete the information immediately.

7. Data Retention

We retain your personal data, spatial data, and interaction history for as long as your account is active or as needed to provide you with the Platform services. If you delete your account, we will delete or anonymize your data within 30 days, except for data we are legally required to retain for tax or accounting purposes. Session data for unregistered guests is routinely purged.

8. Your Rights Under the GDPR

You have the right to access, correct, delete, or restrict the processing of your data, as well as the right to data portability. You can object to our marketing emails at any time by clicking "unsubscribe".

To exercise your rights, contact us at hi@exactlyx.com. You also have the right to lodge a complaint with a supervisory authority regarding the processing of your personal data.