Privacy
Policy.
This Privacy Policy applies to KOZAI, an AI Business Intelligence service operated by VARKOS GROUP LLC (Wyoming, USA) and distributed by VARKOS VIP LTD (London, UK).
Who We Are
KOZAI is an AI platform built for emerging markets, with native African language support and mobile-first payment integration.
Data Controller: VARKOS GROUP LLC · 30 N Gould St Ste N, Sheridan, WY 82801, USA
EU Representative: VARKOS VIP LTD · London, United Kingdom
Contact: support@mykozai.com
Data We Collect
- Account data — name, email, company name, billing address
- Access codes — DIV- codes used to authenticate sessions
- Usage data — queries sent to AI agents (processed in real-time, not stored permanently)
- Payment data — processed by Stripe Inc. We never store card details
- Technical data — IP address, browser type, device info, session tokens
- Communication data — emails you send to our support team
Payment data: when you subscribe via African payment methods (M-Pesa, Wave, Orange Money, Flutterwave, Paystack), payment processing is handled by the respective licensed provider. We do not store full payment credentials.
How We Use Your Data
- To provide and maintain the KOZAI service
- To authenticate access via your DIV- code
- To process payments and send invoices
- To send service notifications and updates
- To improve our AI models and service quality
- To comply with legal obligations
AI Queries & Confidentiality
Your queries to KOZAI agents are transmitted securely and processed in real-time. We do not permanently store the content of your AI conversations on our servers. Session logs are kept for 7 days for debugging purposes, then permanently deleted.
We never use your business queries to train third-party AI models without explicit consent.
Legal Basis (GDPR)
- Contract performance — to deliver the service you subscribed to
- Legitimate interest — security, fraud prevention, service improvement
- Legal obligation — compliance with EU/UK/US law
- Consent — for marketing communications (opt-in only)
Data Sharing
We share data only with trusted service providers necessary to deliver KOZAI:
- Stripe Inc. — payment processing (US, EU certified)
- VARKOS FLUX — Sovereign AI routing infrastructure (anonymized queries)
- Supabase Inc. — database infrastructure (EU region)
- Vercel Inc. — hosting and delivery
We never sell your data. Ever.
Your Rights
- Right to access your personal data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to data portability
- Right to object to processing
- Right to withdraw consent at any time
To exercise any right: support@mykozai.com · Response within 72 hours.
Cookies
KOZAI uses essential cookies for authentication and session management. Analytics cookies are optional and require your explicit consent. We use Iubenda for consent management in compliance with GDPR and ePrivacy Directive.
Data Retention
- Account data: retained for the duration of your subscription + 2 years
- AI query logs: 7 days, then permanently deleted
- Payment records: 7 years (legal requirement)
- Communication logs: 2 years
Security
KOZAI uses enterprise-grade security: TLS 1.3 encryption in transit, AES-256 at rest, row-level security on all database tables, and JWT authentication with short-lived tokens. Access codes (DIV-) add an additional layer of human-verified access control.
Changes to This Policy
We may update this policy. Significant changes will be notified via email 30 days in advance. Continued use after the effective date constitutes acceptance.