Privacy Policy

This is the privacy policy of Jutsu Inc (“Jutsu Inc”, “Jutsu”, “We”, “Our”, or “Us” whether in capital or lowercase letters) Jutsu is a corporation under Jutsu Inc, whose registered office is at 2043 East St #627, Concord, CA 94520.

This Privacy Policy applies to the Website www.jutsu.ai (“Website”) and its associated domains or subdomains (collectively the “Services”). By accessing or using our Services, you undersign that you are, at least 18 years old and that you have read, understood, and agree to the collection, storage, use, and disclosure of your personal information as described herewith. If you disagree with the terms of this privacy policy, please do not access the Website.

In its capacity as a personal data controller, Jutsu carries out its activities in strict compliance with the legal requirements regarding the protection of natural persons in the collection and processing of their personal data. Pursuant to the provisions of Art. 13 and Art. 14 of the General Data Protection Regulation (GDPR), Jutsu hereby provides the necessary information regarding the collection      and processing of your personal data while using this Website. 

This privacy policy is compliant with the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) and the UK GDPR. 

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Website, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Website after the date such revised Privacy Policy is posted.

1. Definitions and key terms

For the purposes of this Privacy policy:

- “Account” means a unique account created for you to access our Service or parts of our Service;

- “Controller” means, under the GDPR, the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

- “Data subject” means a natural person identified or identifiable whose personal data are processed by the controller.

- “IP address” - every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.

- “Personal Data” means, under the GDPR, any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. In CCPA Personal Data are defined  as “personal information” so that Personal Data under this policy correspond to the notion of CCPA “personal information”. 

- “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

- “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

- “Website“ refers to Jutsu Website which is https://jutsu.ai/. 

-“Supplemental Privacy Policy” means privacy policy which regulate different areas of the Website or the features or services.

- “You” (also “your” or “yours”) refers to a person who accesses, views and navigates in the Website;

2. Identity and contact details of the controller

- Controller: Jutsu Inc, whose registered office is at 2043 East St #627, Concord, CA 94520.

- Contact details: E-mail: legal@jutsu.ai

3. Categories of collected and processed Personal Data

Jutsu collects the following categories of Personal Data: 

1. Personal Data given during the creation of the account (email, etc.).

2. Personal Data collected through the use of cookies and Your interplay with the Website. 

3. The Personal Data contained or that might be contained in the prompts that you submit to use the Services. 

4. The Personal Data that you communicate to Us through the contact form or any other means.

4. Purposes and legal basis of processing

4.1 Purposes

Jutsu collects and processes your personal data for the following purposes: 

1. For category 1 above in Article 3, to create an account for You. 

2. For category 2 above in Article 3, to optimize the Website and create a better experience for You. 

3. For category 3 above in Article 3, to deliver the Services to You. 

4. For category 4 above in Article 3, to answer to your queries.  

4.2 Legal basis under GDPR

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. Legal basis are as follows: 

1. For category 1 above in Article 3, the legal basis is that the processing is necessary for the performance of a contract with You (art. 6, b, GDPR).  

2. For category 2 above in Article 3, the legal basis is our legitimate interest to run in the best way the Website (art. 6, f, GDPR).  

3. For category 3 above in Article 3, the legal basis is that the processing is necessary for the performance of a contract with You (art. 6, b, GDPR).  

4. For category 4 above in Article 3, the legal basis is that the processing is necessary for the performance of a contract with You (art. 6, b, GDPR). 

5. Period for which the personal data will be stored

Jutsu stores your personal data for a reasonable period of time and never for longer than it is absolutely necessary. In establishing contractual relations with you, Jutsu stores your personal data throughout the established relations. Normally, Jutsu stores your personal data for 5 (five) years, starting from the beginning of the calendar year following the year of termination of the relationship between us. We may store your personal data for a longer period for reporting, tax and accounting purposes, as well as to protect our legitimate interests. After the expiration of the stipulated terms and if there is no other legal basis for the processing of your personal data, the data will be deleted.

6. Sharing of personal Data

Jutsu will share your Personal Data with the following Processors that provide the underlying AI model or LLM which empowers the Jutsu platform: 

• Anthropic (https://www.anthropic.com/).

• Aura Flow (https://fal.ai/).

• Google (https://ai.google.dev)

• Meta (https://www.llama.com/).

• Mistral (https://mistral.ai/). 

• Open AI (https://openai.com/).

Moreover also Jutsu share Personal Data with the following Processors:

• Company providing cloud services to Jutsu [pls add]

  • AWS: (https://aws.amazon.com)

  • Groq: (htttps://www.groq.com) 

  • SendGrid (https://www.sendgrip.com)

  • MailChimp (https://www.mailchimp.com)

  • MailGun (https://www.mailgun.com/) 

The data processing agreement or PDA between Jutsu and its Processors can be found in its Processor Website. 

Please note that, although Jutsu access the underlying AI model Processors through API and this should be guarantee that Personal Data contained in the prompts inserted in the Jutsu platform are not used to train the Processors AI models, since the same functionality of the AI systems is highly complex and it still largely being developed, we cannot guarantee that the Personal Data contained in the prompts that through Jutsu are sent to the Processors AI Model are used, even partially or indirectly, to train the Processors AI models. We, therefore, recommend you to not include in the prompts any Personal Data whether sensitive or not. 

7. Disclosure and transfer of personal data to the USA under GDPR

EU resident are aware that by using the Website and sending information and/or your personal data to Jutsu you acknowledge that part of your personal information may be processed in the United States. The UE Commission has recently issued an adequacy decision in relation to the USA but Jutsu is not a member of the privacy shield and, therefore, data will be transferred to the USA on the basis of the consent of data subject or if the transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of pre-contractual measures taken at the data subject's request to pursuant to Article 49, 1st paragraph, a and b, GDPR. By communicating your personal data to Jutsu you hereby fully and irrevocably agree that part of your data may be transfered to the USA. 

In strict compliance with the legal requirements, Jutsu may disclose or transfer your personal data to the following recipients under particular circumstances:

• Agents, businesses, or service providers who process your personal information for providing the Services to you. The respective receiving third parties shall observe and adhere to strict confidentiality agreements. We are committed to maximum protection of your personal information, therefore, we only deal with ethical suppliers and business partners who demonstrate similar values and are bound by privacy laws of the same standard.

• Law enforcement agencies and/or other public authorities (e.g., a court or a government agency) when required to do so by law.

7. Cookie policy

We are using cookies to improve the quality of the client’s experience on the Website. The cookie, a small text file that is stored on the customer’s computer for record-keeping purposes, can be used as an identification card: a cookie is unique to your computer and only the server that gave it to you can read them. Using traffic log cookies, we can identify and monitor what pages are mostly used. This will help us to analyze data about Website traffic and later improve our Website. Most existing web browsers can automatically receive cookies, but you can change your browser settings and decide whether to accept cookies or not. There is one important characteristic – cookies do not provide Websites with personal information (such as email addresses or other information) without your permission. Once you provide a Website with personal information, your information can be linked to the data stored in the cookie. You should remember that we will not share your personal information with third parties if we do not have permission from you or if we are not required to do it by law. Our main goal is to make our Website as efficient for you as we can. We can personalize your web experience on our Website with cookies: we will remember you as an individual and what content was interesting for you, and as a result, we can remove web pages that are not important and offer you the most popular products and services based on your web preferences (for example we may send you promotional emails with information about our new products, new special offers, special deals, etc.).

8. Your privacy rights 

As a data subject, under the GDPR and CCPA you have the following rights in relation to the personal data you provide:

• The right to be informed – you have the right to receive appropriate transparent information about the processed personal data, the purposes and basis of the processing, the recipients or categories of recipients to whom your personal data has been or will be disclosed, the storage period, as well as any other information about your personal data.

• The right of access – you have the right to access your personal data processed by Jutsu, as well as to request a copy of the personal data in a structured, commonly used format.

• The right to rectification – you have the right to request rectification of your personal data if it is incomplete, inaccurate or out of date.

• The right to erasure (the right to be forgotten) – you have the right to request the erasure of your personal data under particular circumstances: it is no longer necessary in relation to the purposes for which it was collected; you have withdrawn your consent to the processing, and there is no other legal basis for processing; when your personal data has been unlawfully processed; in the presence of other legal grounds.

• The right to object – you have the right to object to the processing of your personal data.

• The right to restrict processing – you have the right to withdraw your consent to the processing of your personal data by the controller or the processor at any time and free of charge.

• The right to data portability – you have the right to request the transfer of your personal data to another personal data controller when technically feasible.

• Right of protection – you have the right to defend your rights by judicial or administrative means if you believe that your rights as a data subject have been infringed in any way.

• Rights related to automated decision-making and profiling – you have the right to oppose to any automated decision-making and profiling. 

9. Exercising rights related to personal data

At any time, you can withdraw your consent or object to the processing of your personal data and exercise your other rights as a data subject. For this purpose, you should send us a notice using one of the contact details provided in this policy.

Upon receipt of such a notice, Jutsu will provide information regarding the actions taken within one month of receipt. If necessary, this period may be extended by another two months, considering the complexity and number of requests made by one data subject. We will inform you of any extension within one month of receiving the notice, stating the reasons for the extension. 

Jutsu will provide the necessary information in relation to the notice only if the sender has been properly identified. Jutsu is not obliged to respond to a notice in the event that it is unable to identify the data subject or his/her credentials. We may request the provision of additional information and documents necessary to confirm the identity and authority of the data subject when there are reasonable concerns.

Your questions, comments, requests or complaints regarding this Privacy Policy shall be addressed to legal@jutsu.ai

If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to the supervisory authority of the place where you reside. 

If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.