Privacy Policy

INVICTUS AI CORPORATION

Effective Date: July 1, 2026 | Last Updated: June 19, 2026

1. Introduction

Invictus AI Corporation, a Nevada corporation (“Invictus AI,” “we,” “our,” or “us”), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Policy explains how we collect, use, disclose, and safeguard information about you when you access or use our products, services, applications, platforms, APIs, and websites, including Verena™ and any other services operating under the Invictus AI brand (collectively, the “Services”).

This Privacy Policy is incorporated into and forms part of our Terms of Service. By using our Services, you acknowledge that you have read and understood this Policy. If you do not agree with our practices, please do not use the Services.

2. Scope

This Policy applies to information we collect:

On and through our websites, including invictus.ai and verena.ai;

Through our software products, platforms, APIs, and AI-powered features;

When you register for an account, subscribe to a plan, or otherwise interact with our Services;

In email, electronic messages, and other communications between you and us.

This Policy does not apply to information collected by our affiliated entities under their own privacy policies, including Invictus Counsel, PLLC, which maintains a separate Privacy Policy at invictuscounsel.com/privacy.

3. Information We Collect

We collect several categories of information about you, including:

3.1 Account and Registration Data

Information you provide when creating an account or managing your profile, including name, email address, phone number, company name, job title, billing information, and any other information you choose to provide.

3.2 Usage Data

Information about how you interact with our Services, including features accessed, queries submitted, AI outputs generated, session duration, error logs, and clickstream data.

3.3 User Content and Input Data

Any text, files, documents, images, audio, video, or other content you submit to or through the Services (“User Content”), including content processed by AI features. Please see Section 5 regarding how User Content may be used in connection with AI model development.

3.4 Technical Data

IP address, browser type and version, device identifiers, operating system, referral URLs, and other technical information collected automatically when you use the Services.

3.5 Communications Data

Content of emails, chat messages, support tickets, and other communications you send to us.

3.6 Behavioral and Inferred Data

Preferences, interests, and characteristics we infer from your usage of the Services, including patterns of interaction with AI features.

3.7 Third-Party Data

Information we receive from third-party partners, data providers, social media platforms, or identity verification services when you connect such services to your account.

4. How We Use Your Information

We use the information we collect for the following purposes:

To provide, operate, maintain, and improve the Services and AI features;

To personalize your experience and deliver relevant content and features;

To train, fine-tune, evaluate, and improve our AI models and algorithms (subject to your opt-out rights described in Section 5);

To communicate with you about your account, transactions, support requests, and updates to our terms and policies;

To send marketing, promotional, and informational communications (you may opt out at any time);

To conduct research, analytics, and product development;

To detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms of Service;

To comply with legal obligations, respond to legal process, and enforce our rights;

To protect the safety and security of our users, employees, and the public.

5. Artificial Intelligence and Model Training

Invictus AI develops and operates AI products including Verena™. Improving our models requires access to data. This section explains our practices in full.

5.1 Default Use for Training

By default, User Content and usage data you generate through the Services may be used to train, fine-tune, and evaluate our AI models and algorithms. This helps us improve the quality, safety, and accuracy of our AI features over time.

5.2 Your Opt-Out Right

You may opt out of having your User Content and usage data used to train AI models at any time. To opt out, email privacy@invictus.ai with the subject line “AI Training Opt-Out.” We will honor opt-out requests within 30 days. Opting out does not affect improvements derived from aggregated, anonymized, or de-identified data that cannot reasonably be linked to you.

5.3 Aggregated and De-identified Data

Regardless of opt-out status, we may use aggregated, anonymized, or de-identified data for product development, research, benchmarking, and industry insights, provided such data cannot reasonably identify you.

5.4 Feedback

If you provide feedback, suggestions, or ideas regarding the Services (“Feedback”), such Feedback is non-confidential and we may use it for any purpose, including AI improvement, without restriction or compensation.

6. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

6.1 Service Providers

With vendors and contractors who perform services on our behalf, such as cloud hosting, payment processing, analytics, and customer support, subject to appropriate confidentiality and data protection obligations.

6.2 Business Partners

With trusted business partners where you have consented to such sharing or where sharing is necessary to provide an integrated service.

6.3 AI and Data Providers

With third-party AI model providers, data annotation services, and technology partners to operate or improve the Services.

6.4 Legal and Regulatory

With courts, regulators, law enforcement, or government authorities when required by applicable law, court order, or legal process, or when we reasonably believe disclosure is necessary to protect rights, property, or safety.

6.5 Business Transactions

In connection with a merger, acquisition, sale of assets, financing, or similar transaction. We will notify you of any such transfer in advance where reasonably practicable.

6.6 Aggregated and De-identified Data

We may share aggregated, anonymized, or de-identified data with any third party for research, analytics, or other lawful purposes.

6.7 With Your Consent

With any other third party where you have provided explicit consent.

7. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar technologies to collect usage data, analyze performance, personalize your experience, and improve our Services.

Essential Cookies: Required for the Services to function. These cannot be disabled.

Analytical Cookies: Help us understand how you interact with the Services.

Functional Cookies: Remember your preferences and settings.

Marketing Cookies: Deliver relevant communications and measure campaign effectiveness.

You may manage cookie preferences through your browser settings. Disabling certain cookies may impair functionality. In jurisdictions requiring consent, we will present appropriate cookie preference options.

8. International Data Transfers

Invictus AI is headquartered in the United States and processes data primarily in the United States. If you access the Services from outside the United States, your information may be transferred to and processed in the United States and other countries that may have different data protection laws than your jurisdiction.

For transfers from the European Economic Area, United Kingdom, or Switzerland, we rely on appropriate safeguards including Standard Contractual Clauses approved by the European Commission. You may request information about our transfer mechanisms by contacting privacy@invictus.ai.

9. Data Retention

We retain personal information for as long as your account is active, as necessary to provide the Services, as required by applicable law, or as reasonably necessary for legitimate business purposes, including dispute resolution, enforcement of agreements, security, fraud prevention, and audit purposes.

Upon account termination, we will delete or anonymize your personal information within a commercially reasonable time, except where retention is required by law or necessary for the purposes described above.

10. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

10.1 Rights Available to All Users

Access: Request a copy of the personal information we hold about you.

Correction: Request correction of inaccurate or incomplete personal information.

Deletion: Request deletion of your personal information, subject to legal and contractual obligations.

Opt-Out of AI Training: Opt out of having your data used for AI model training (see Section 5.2).

Opt-Out of Marketing: Unsubscribe from marketing communications at any time.

10.2 EEA/UK Residents — GDPR

Data Portability: Receive your personal data in a structured, machine-readable format.

Restriction of Processing: Request that we restrict processing of your data in certain circumstances.

Objection to Processing: Object to processing based on legitimate interests or for direct marketing.

Complaint: Lodge a complaint with your local data protection authority.

Our legal bases for processing: performance of contract; your consent (including for AI training and marketing); legitimate interests (improving Services, security, fraud prevention); and compliance with legal obligations.

10.3 California Residents — CCPA/CPRA

California residents have the right to: (i) know what personal information is collected, used, shared, or sold; (ii) delete personal information held by us; (iii) opt out of the sale or sharing of personal information (we do not sell personal information); (iv) non-discrimination for exercising CCPA rights; and (v) correct inaccurate personal information. To submit a verifiable consumer request, contact privacy@invictus.ai. We will respond within 45 days (extendable by 45 days where necessary with notice).

10.4 Submitting Requests

To exercise any privacy right, contact privacy@invictus.ai. We may need to verify your identity before processing your request. We will respond within timeframes required by applicable law.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including encryption of data in transit and at rest, access controls and authentication requirements, regular security assessments, and employee training on data protection. No method of transmission over the internet or electronic storage is completely secure. In the event of a data breach affecting your rights, we will notify you as required by applicable law.

12. Children’s Privacy

Our Services are not directed to or intended for use by children under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have inadvertently collected such information, we will promptly delete it. If you believe we may have collected personal information from a child under 18, please contact legal@invictus.ai.

13. Third-Party Links and Services

Our Services may contain links to or integrations with third-party websites and services not operated by Invictus AI. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through our Services.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by: (i) posting the revised Policy on our website with an updated “Last Updated” date; (ii) sending notice to the email address associated with your account; or (iii) displaying a notice within the Services. Your continued use of the Services after the effective date of any change constitutes your acceptance of the revised Policy.

15. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

Invictus AI Corporation

Privacy Team

Email: privacy@invictus.ai

Website: https://invictus.ai